TaxTMI 
TaxTMI 
2017 (8) TMI 1217
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....mber ( Judicial ) For the Applicant : Shri S R Dixit, Shri A Nainavati, Shri S Vyas, Shri Dhaval Shah, Shri Jigar Shah, Shri N K Oza, Shri H Bhandari And Shri Y B Desai, Advocates For the Respondent : Shri Sameer Chitkara, Authorised Representative ORDER Per : Dr D.M. Misra, All these appeals are filed against respective Orders-in-Appeal passed by concerned Commissioner(Appeals),Central Excise, Customs & Service Tax, since involve a common question of law, are taken up together for disposal. 2. The common issue involved in these appeals relates to admissibility of CENVAT Credit of the Service Tax paid on 'Courier Service' pertaining to the period prior to 01.4.2011 and thereafter. The Ld Advocate Shri S. R. Dixit f....
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....ents relating to sale, advertisement, accounting, etc., are necessary and part and partial of the business of manufacturing activity. It is his plea that the activity of marketing of manufactured goods, cannot be separated from the activity of manufacture of goods, thus, sending the documents relevant to marketing, samples of finished goods to the customers for approval, opinions, reports, reply to the querries of tax authorities, govt. departments are services fall within the scope of the definition of input services. The Ld Advocate further submitted that even though the expression of activities relating to business has been deleted in the amended Rule, however, the other activities viz., Advertisement, Sales Promotion, Market Research, A....
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....dered to fall within the scope of 'Input Service', being strictly connected to their business of activity and not directly related to the manufacturing activity, hence, service tax paid on 'Courier Service' is inadmissible to credit after 01.04.2011. 5. Heard both sides and perused the records. 6. The core issue for determination is: whether the appellants are eligible to CENVAT credit of the Service Tax paid on 'Courier Services'. The present appellants are manufacturer of excisable goods and utilized the 'Courier Services' in sending the Samples, Documents and Finished Goods to their customers. Revenue has not seriously disputed admissibility of Cenvat Credit on the 'Courier Services' for the ....
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....ion, makes it clear that though the expression activities relating to business, such as has been deleted, but the illustrative services viz., Accounting, Auditing, Financing, Recruitment and quality control, Coaching/training, Computer Networking, Credit Rating, Share Registry, Legal Services, Security, Business Exhibition etc., even though directly not related to manufacturing activity, being not used inside the factory premises, but continued to remain in the said definition of input service. Needless to mention that these services are even though not directly linked to the manufacturing activity in the factory premises of the assessee but connected or related to the business of manufacturing activity which also involve marketing/sale of ....