TaxTMI 
TaxTMI 
2018 (11) TMI 1027
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.... 2. Today when the matter came up for hearing, Ld. Advocate Shri. M. Kannan appeared for the appellant and Ld. AC (AR) Shri. R. Subramaniyan appeared for the Revenue; I have heard the rival contentions, perused the documents placed on record and have gone through the decisions relied on during the course of hearing. 3.1 The details of input services involved against which the credit was sought by the assessee but denied by the Revenue, for the relevant periods of dispute, are as under : Sl. No. Appeal No. Period of Dispute Input Service Credit/Penalty (in Rs.) 1. E/42208/2017 12/2014 to 03/2015 * Rent paid for storage of materials at TVS Logistics godown, Puzhal, Chennai (16,352/-) * Penalty (8,176/-) 2. E/42209/2017 12/2....
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....ity, no documentary evidence was produced in support of their claim. 5. I have to therefore dismiss the above ground of the appellant for the reason that the appellant has not produced any documents in support before the lower authorities and the only irresistible conclusion that could be drawn is that the appellant has not proved nexus and therefore hit by Rule 2(l) as amended. 6. With regard to the Manpower Supply Service which is a common ground in respect of Appeal Nos. E/42209, 42210, 42211 & 42212/2017, it is submitted by the Ld. Advocate that the above service was related to PF/ESI and professional service since the wages paid to the labourers were subject to PF/ESI which formed part of the total service cost against which service ....
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....ed to such sub-contractor and therefore, the said service received would always be in relation to processing of appellant's excisable goods at its sub-contractor's premises. 9. Per contra, Ld. AR supported the findings of the lower authorities. 10. I have considered the rival contentions. I find from the impugned Order that as observed hereinabove, the only reason given by the Revenue is that the service was rendered at the sub-contractor's end. It is not the case of the Revenue that the same is not an eligible input service or that the above service was hit by the amended Rule 2(l) of the CENVAT Credit Rules, 2004. I find this observation relevant because the Commissioner (Appeals) has himself observed, without being certain, that "such ....