2018 (12) TMI 722

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....utiny of the appellant's records at their corporate office, they had found that the appellant had shut down its manufacturing operations and also closed its unit at Alandur and shifted to Madhavaram as Plant-III. It was also noticed by the Audit that the appellant had availed CENVAT Credit on input services rendered by M/s. CBRE South Asia Ltd. (hereinafter referred to as 'M/s. CBRE') with whom the appellant had entered into an agreement, to provide services to the appellant in identifying a suitable buyer for the appellant's factory premises i.e., land measuring 5.97 acres at Town Survey No. 77 (part) Old Survey No. 8 (part) Adambakkam Village, Alandur Taluk, during the month of April 2015. As per the agreement, the fee payable to M/s. CBR....

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.... the above detailed reply, wherein the adjudicating authority accepted the pleadings of the appellant and dropped the proceedings. Aggrieved by the same, the Revenue preferred an appeal before the Commissioner of G.S.T. & Central Excise (Appeals-II), Chennai, who vide impugned Order-in-Appeal No. 199/2018 dated 27.04.2018 allowed the Department Appeal against which, the present appeal has been filed by the assessee. 3. Today when the matter came up for hearing, Ld. Advocate Ms. S. Sridevi appeared for the assessee while Ld. AC (AR) Shri. L. Nandakumar represented the Department. 4. During the course of hearing, Ld. Advocate while reiterating the submissions made before the lower authorities, has also relied on the following decisions ....

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.... of Rule 2(l) is extracted below: "*(l) "input service" means any service, - (i) used by a provider of [output service] for providing an output service; or (ii) used by a manufacturer, whether directly or indirectly, in or in relation to the manufacture of final products and clearance of final products upto the place of removal, and includes services used in relation to modernisation, renovation or repairs of a factory, premises of provider of output service or an office relating to such factory or premises, advertisement or sales promotion, market research, storage upto the place of removal, procurement of inputs, accounting, auditing, financing, recruitment and quality control, coaching and training, computer networking, credi....