https://www.taxtmi.com/caselaws?id=798798 Extended limitation for alleged short reversal of CENVAT credit requires fraud, collusion, wilful misstatement, suppression, or contravention intended to evade duty; reversals disclosed in returns and capable of verification do not establish such intent. Proportionate reversal under Rule 6 is confined to common credit attributable to inputs or input services used for both taxable and exempted activities, excluding credit exclusively used for taxable outputs; the revised formula is treated as clarificatory. Trading involves transfer of title in goods, is excluded from the definition of service, and cannot be treated as an exempted service merely because of the negative-list framework. Consequently, a demand based on total-credit reversal is legally unsustainable. en-us Thu, 10 Sep 2026 00:00:00 +0530 Sat, 12 Sep 2026 08:41:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798798 Extended limitation for alleged short reversal of CENVAT credit requires fraud, collusion, wilful misstatement, suppression, or contravention intended to evade duty; reversals disclosed in returns and capable of verification do not establish such intent. Proportionate reversal under Rule 6 is confined to common credit attributable to inputs or input services used for both taxable and exempted activities, excluding credit exclusively used for taxable outputs; the revised formula is treated as clarificatory. Trading involves transfer of title in goods, is excluded from the definition of service, and cannot be treated as an exempted service merely because of the negative-list framework. Consequently, a demand based on total-credit reversal is legally unsustainable. Case-Laws Service Tax Thu, 10 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798798