TaxTMI 
TaxTMI 
2018 (11) TMI 416
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....DER Per: Ramesh Nair The issue involved in the present case is that the whether the appellant is entitled for Cenvat Credit in respect of supply of tangible goods service used for export of goods. The appellant have taken ISO Tank Container an rental basis from M/s Combipass Sas, Fance. The appellant have paid service tax under reverse charge mechanism. The ISO Tank Container was being used fo....
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....over all manufacturing and supply of goods. He further submits that the service restricted up to place of removal for the purpose of cenvat credit is only in respect of goods transport service. In the present case admittedly the service is not good transport service but it is the supply of tangible goods, therefore, restriction provided in respect of input service up to place of removal shall not ....
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.... come to the conclusion that since this service is used for removal of goods beyond the place of removal then credit is not admissible. The relevant findings of the impugned order reproduced below: "I have gone through the grounds of appeal in memorandum, statement of facts, submissions made during the course of personal hearing and records available on file. The issue in this case is as to wheth....
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....e 3 limbs of the definition:- 1) The service is used in or in relation to the manufacture of final product. 2) The service is used for clearance of final product up to the place of removal. 3) The services mentioned in the inclusion clause of the definition. In the present case, the supply of tangible goods i.e. renting of ISO Tank Container is not used in relation to the manufacture of final ....