2022 (4) TMI 422

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....espect of head office but the head office is operating exclusively for the activity relating to the factory wherein the manufacturing process is carried out therefore, the service were, even though received in head office, is in relation to the activity of manufacturing in the factory, therefore, credit is admissible. He placed reliance on the following judgements: • Deepak Fertilizers and Petrochemicals Corp. 2013 (32) STR 532 (Bom.) • Balkrishna Industries Ltd. 2015 (39) STR 861 (Tri. Del.) • Jindal Pipes Ltd. 2013 (31) STR 861 (Tri. Del.) • HID India Pvt Ltd. 2017 (52) STR 385 (Tri. Bang.) • Bharat Fritz Werner Ltd. 2011 (22) STR 429 (Tri. Bang.) • Huhtamaki PP....

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....d outside the factory, it cannot be said that the service received and used in head office does not relate to the manufacturing activity. Had this same office is maintained in the factory premises, there would not have any objection by the Revenue. The location of the head office is immaterial so long it is used only for the operation of the factory's activities, therefore, any service received in head office is in relation to the manufacturing activity of the appellant. This specific issue has been considered by this Tribunal in various judgements, some of them are reproduced below: • In case of Jindal Pipes Ltd. Tribunal has observed as under:  "6. So far as the services of travel agents is concerned, there is n....

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....nput service as contained in 2(l) of CCR, 2004 has been given wide interpretation to include any service used by the manufacturer whether directly or indirectly, in or in relation to the manufacture of final product. In support of his submission, he relied upon the following authorities : (i) CCE v. Ultratech Cement Ltd. : 2010 (20) S.T.R. 577 = 2010 (260) E.L.T. 369 (Bom.) (ii) Coca Cola India Pvt. Ltd. v. CCE : 2009 (15) S.T.R. 657 = 2009 (242) E.L.T. 168 (Bom.) 3.1 The learned counsel for the appellant further submitted the authorities of KPMG v. CCE, New Delhi reported in 2014 (33) S.T.R. 96 in which the Hon'ble CESTAT, New Delhi has held that car parking facilities is held to constitute input service and elig....