2022 (5) TMI 1241

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....CIAL) Shri Dharmendra Kumar Rana, Advocate for the Appellant Ms. Anuradha S. Parab, Assistant Commissioner, Authorised Representative for the Appellant ORDER Denial of CENVAT credit by the Commissioner of Central Excise & Service Tax, Pune-I on input services on the ground that those were not received at the factory of Appellant but at External Warehouse having separate First Stage Dea....

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....elating to meagre trading activity of 0.35% was made in the Audit report dated 08.04.2015 but Appellant was issued with show-cause notice suggesting denial of CENVAT credit of Rs.1,46,11,468/- with interest and penalties on the allegation that input services against those were not received at the factory of the Appellant but at the EWH which had a separate registration, from where trading was unde....

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....nate to trading activity in terms of Rule 6(3A) and no ineligible credit of input services was availed by the Appellant. He further argued that against Order-in-Appeal passed by the Commissioner of Central Tax (Appeals-I), Pune setting aside another Order-in-Original dated 13.02.2017 for the period from November, 2014 to March, 2016 holding that the entire input services were natural input service....

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....l also was not challenged by the Department and that attained finality. Learned Counsel for the Appellant, with reference to judicial decision reported in Vako Seals Private Limited Vs. CCE [2015 (40) STR 594 (Tri.-Mumbai)], Raymond Limited Vs. CCE [2017 (47) STR 142 (Tri.- Del.)], Adbur Private Limited Vs. CST [2017 (5) GSTL 334 (Tri.- Del.)], Shrirarm General Insurance Company Limited Vs. CCE [ ....