2016 (12) TMI 223

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.... basis of the invoices issued by their head office at Chennai as input service distributors, in respect of the services of advertisement and publicity, godown rent, annual maintenance charges, customer care , rent a-cab service, courier service, communication service, C & F service, logistics service, business support service and insurance service etc. The Department was of the view that in addition to manufacturing, the appellant were also engaged in trading activity and these services had also been used in connection with their trading activity. 1.1 When the appellant could not give break-up of the value of input services used for manufacturing activity and for trading activity separately, show cause notices were issued for denying the....

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....n used  by the manufacturer for final product or by the provider of output service for providing output service; or in other words, such inputs/input services are used directly or indirectly by the manufacturer in relation to manufacture and clearance of final product. The provisions of law relating to Cenvat Credit Rules as per definition given for input under Rule 2(k) and for the input service under Rule 2(l) of Cenvat Credit Rules are very clear and unless such inputs/ services fulfill the definitional criteria of input or input service, the invoices issued by the ISD (Input Service Distributor) cannot legally distribute the credit of service tax paid on the said services. 4.1 The impugned order points out that the appellant has....