2020 (3) TMI 263

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....ed by the appellant for its clients, viz. M/s. Actavis Elizabeth LLC and M/s. Actavis Group HF, Iceland abroad. ii. Denial of cenvat credit on input services availed by the appellant viz. catering services to the tune of Rs. 16,49,367/- for the period May 2006 to September 2009. iii. Denial of cenvat credit on the service tax paid on input services, viz. rent paid for the premises acquired by them at Jakkur, amounting to Rs. 22,16,453/- for the period July 2007 to March 2009. 3. Briefly the facts of the present case are that the appellant conducts clinical and pharmaceutical research on new drugs through testing and analysis of their effect on human beings / volunteers with the resultant data being evaluated by experts ....

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....ice was received towards staff lunch and canteen expenses incurred by the appellant and the same cannot be treated as input service for providing the output service of technical testing and certification/analysis. 4.3. As regards input service of renting, admitted fact is that premises were taken by the appellant for their business purposes and the same were undergoing modifications / repairs as per requirements of the appellant, and the appellant was yet to commence business activity from the said premises. Hence it appeared that the service tax paid towards renting cannot be treated as input service for providing output service. Accordingly, show-cause notice dt. 24/03/2010 was issued invoking extended period of limitation for the peri....