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2018 (6) TMI 316

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....g been claimed against photocopies of the bills of entry and without receipt at their premises, and of `3,45,612 against bills of entry pertaining to clearance by their other unit which is assailed now. 2. Learned Counsel for appellant places reliance on the decision of the Hon'ble High Court of Gujarat in Commissioner of Central Excise & Customs, Vadodara - II v. Steelco Gujarat Ltd [2010 (255) ELT 518 (Guj)] upholding the decision of the first appellate authority which had allowed the credit thus  '2 We have considered grounds raised in the memo of Appeal and also perused the orders passed by the authorities below. The learned Commissioner (Appeals) vide his order dated 20-2-2008 has observed that as the original/duplicate invo....

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....ect of inputs/input services which have been received prior to registration. The Cenvat Credit Rules contain no express restriction on distribution of credit earned prior to taking the registration by the ISD also. Hence, the ISD can avail credit of service tax paid on input services received prior to registration and moreover, in this case there is only one manufacturing unit of the appellant and the Revenue was well aware of this fact from the very beginning. The authorities cited by the learned counsel for the appellant squarely cover the case of the appellant. In view of this, the appeal of the appellant is allowed with consequential relief, if any.' the contest the decision of the lower authorities to disallow CENVAT credit merely f....