AI Drafter 
TaxTMI 
TaxTMI 
2022 (11) TMI 325
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.... of Rs. 66,96,62,836/- (actual amount of Rs. 67,00,80,012/- ) which is answerable to the Commissioner Service Tax-1, Mumbai is decided as under : 5.1 The demand for inadmissible Cenvat Credit availed and utilized by the notice as above is confirmed to the extent of Rs. 36,42,20,169/- Rs. 34,37,05,962/-(Para 4.10.1) + Rs. 2,05,14,207/-(Para 4.7.6.)] and I order the recovery of the said amount under the provisions of Rule 14 of CCR, 2004 read with the proviso to Section 73(1) of the Finance Act, 1994 against M/s. Tata Sons Ltd. The balance amount of demand is ordered to be dropped as discussed in para 4.3, 4.6 and 4.10 supra. 5.2 I hereby order the payment of interest at the appropriate rate under Rule 14 of the CCR, 2004 read with Section 75 of the Finance Act, 1994 on the above service tax amount of Rs. 36,42,20,169/- confirmed against M/s. Tata Sons Ltd as above. 5.3 I impose penalty equal to 100% of CENVAT credit wrongly availed and utilized which comes to Rs. 36,42,20,169/- Penalty would be payable under Rule 15(4) of CCR period from 1.10.2008 to 27.02.2010 and under Rule 15(3) of CCR for the period from 1.3.2010 to 31.3.2013. 6. This order is issued without prejudic....
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....to have been used for providing the taxable services. Accordingly a Show Cause cum Demand Notice dated 16.12.2014 was issued to the appellant asking them to show cause as to why: "a. The CENVAT credit amounting to Rs 66,96,62,836/- as detailed in Annexure to the show cause notice should not be demanded and recovered from them under Rule 14 of Cenvat Credit Rules, 2004 read with proviso to Section 73 (1) of the Finance Act, 1994. b. Interest at the appropriate rate under Rule 14 of Cenvat Credit Rules, 2004 read Section 75 of the Finance Act, 1994 should not be recovered from them. c. Penalty should not be imposed on them under the provisions of Rule 15 (3) or 15 (4) of Cenvat Credit Rules, 2004 as applicable during the relevant period read with Section 78 of the Finance Act, 1994" 2.5 The show cause notice was adjudicated as per the impugned order referred in para 1 above. 2.6 Aggrieved by the order, both Appellant and Respondent have filed appeal before the tribunal. 3.1 We have heard Shri Vikram Nankani, Sr. Advocate, with Shri Rohit Jain, Shri Nawz Pal, Advocates and Shri Jignesh Ghelani, C.A. for the appellant and Shri Shamboo Nath, Principal Commissioner, Aut....
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.... under Rule 2(e) of CCR was amended w.e.f. 01.04.2011 to insert the Explanation clarifying that 'exempted services' include trading. The substantive change in law introduced vide the said amendment cannot be given retrospective effect and hence, reversal of Cenvat Credit on account of trading is not warranted for the period prior to 01.04.2011. Reliance is placed on the following decisions holding that reversal on account of trading is not required to be made for the period prior to 01.04.2011: • Trent Hypermarket Ltd. [2019 (6) TMI 1327 - CESTAT MUMBAI] • Adani Energy Ltd [2022 (3) TMI 696 - CESTAT AHMEDABAD] • Panacea Biotec Ltd. [2019 (1) TMI 1245 - CESTAT NEW DELHI] • As per the Department appeal, value of exempt service on account of trading in securities must be the sale value of the securities during the period prior to 01.04.2011 and the margin scheme introduced vide Explanation to Rule 6(3D) will only apply for the period post 01.04.2011. • In M/s Mercedes Benz India Pvt. Ltd [2020 (3) TMI 146 - CESTAT MUMBAI]. it was held that the entire sale value of the securities cannot be regarded as the value of....
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....ue Services Pvt. Ltd., 2019 (8) TMI 1174 - MADRAS HIGH COURT; • The Commissioner of Central Tax, Bangalore North Commissionerate v. M/s ABB Limited, 2022 (6) TMI 1212 - KARNATAKA HIGH COURT. • Ghatge Patil Industries Ltd v. C.C.G. St., Kolhapur, 2020 (10) TMI 437 - CESTAT MUMBAI; • The extended period is not invokable even in respect of period post 01.04.2011 as the Appellant has submitted all the details to the Department and cooperated with the investigation and hence, there is no question of suppression of facts or fraud involved in the present case. In this regard, detailed submissions are made at ground IX of the Appeal. Further, reliance is placed inter alia on the decision in Trent Hypermarket Ltd. v. Commissioner Of Central Excise, Pune-III, 2019 (6) TMI 1327 - CESTAT MUMBAI where it was held that extended period is not invokable in respect of the present issue in question even for the period post 01.04.2011 • There are computational errors in the order. The Cenvat credit availed by the Appellant has been considered higher by Rs. 1,77,99,483/-. the percentage of credit attributable to taxable services arrived at by the OIO....
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....hs • During the years 2008-09 the appellants have booked expenditure Rs.290 cr. whereas the income from the Brands promotion is Rs. 291cr. The claim of the appellant that entire expenditure incurred for promotion of brand only is incorrect. The expenditure of Rs. 290 Cr. have been incurred on earning of entire income which also includes income from sale of investments/securities. • The appellant have taken the input service credit of Rs.66.96 cr during the period 2008-2009 to 2012-2013. Allegation of the Department is that the appellant have taken the credit of input services used also for exempted services/non taxable activities, therefore the entire credit is not admissible. Adjudicating Authority have clearly found (para 4.7.6 of OIO) that 21 input services are used exclusively for the core activity such as generating revenue from sale of investment and assets. Such input services are management consultancy, manpower supply, business support, etc. are primarily used for its core business and certain services i.e construction related service are excluded from the definition u/r 2(1) of CCR. The total credits on this count denied are Rs. 2.05 cr. ....
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.... to be severed before sale or under the contract of sale;' Thus, sale of goods cover the sale of stock and share (securities). • Securities' has been defined u/s 65(93) of the Finance Act, securities has the meaning assigned to it in clause (h) of Section 2 of Securities Contract (Regulation) Act, 1956. Clause (h) of Section 2 of Securities Contract (Regulation) Act, 1956 (42 of 1956) defines the Securities as (h) "securities" include (1) shares, scrips, stocks, bonds, debentures, debenture stock or other marketable securities of a like nature in or of any incorporated company or other body corporate; (ia) derivative; (ib) units or any other instrument issued by any collective investment scheme to the investors in such schemes; (ic) security receipt as defined in clause (zg) of section 2 of the Securitisation and Reconstruction of Financial Assets and Enforcement of Security Interest Act, 2002; (id) units or any other such instrument issued to the investors under any mutual fund scheme; (ie) Government securities; (iia) such other instruments as may be declared by the Central Government to be securities; and (iii) Rights or inte....
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....goods as defined under Section 65(50) of the Finance Act, 1994 read with Section 2(7) of Sale of Goods Act, 1930 and Section 65(25) of the Finance Act, 1994. • The appellants have been trading securities including units of the mutual funds and therefore as per provision of Rule 2(e) of CCR 2004 and catena of Tribunal decisions trading of goods is considered as "exempted services."/ Non- service activity. Therefore it was argued before the bench that sale and purchase of securities are to be considered as trading of goods which are exempted service/ non- service activities. The Appellant ought to have reversed the credit on pro-rata basis (upto 1.4.2011) and as per formula prescribed u/r 6(2)/6(3A) of CCR, 2004. • Following judgments of Tribunal/ High Court were relied upon on trading of goods wherein judicial decisions have been treated as exempted service/non-service activity and order on reversal of credit either on pro-rata basis or u/r/ 6(3) / 6(3A) of CCR, 2004. • Mercedes Benz India Pvt Ltd. [2014 (36) STR 704 (Tri. Mum)] • Synise Technologies Ltd. [2015 (36) STR 903 (Tri. Mum)] • Mercedes Benz India Pvt L....
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....l owner Company of the brand name TATA'. Their main source of income is the investment income in the form of dividends and interest received from the money invested in the group companies. In addition they also charge the group companies for use of the brand name "TATA" and the said income is known as Brand Promotion Income. They are paying service tax on the said brand promotion income in the category of Intellectual Property Rights Services. They are availing Cenvat credit on various input services claiming that these are used for providing their output service of Brand Promotion Service. The department has issued a show cause notice proposing to deny CENVAT credit availed by them on the ground that input services are not being used for providing taxable output service. In other words, the input services has no direct or indirect connection with the brand promotion activity on which they are paying service tax, therefore, availment of CENVAT credit is irregular. On this point, the Noticee has argued that they are not claiming CENVAT credit on services which are exclusively used for investment activity. In other words, they are taking CENVAT credit on the 'input services&#....
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.... a particular service, the CENVAT credit is being denied or allowed for the full amount. The total amount of CENVAT credit for the first half of the Financial Year 2008-09 comes to Rs.6,14,68,326/-pertaining to the period April to September, 2008, which is beyond the period of five year and ordered to be dropped. 4.5. Further, I also observe that the total Cenvat Credit amount demanded in the Show cause notice is Rs. 66,96,62,836/-. However I find that the actual amount of demand amount should have been Rs.67,00,80,012/-. The difference of Rs. 4,17,176/- has occurred due to totaling mistake of the demand amount for FY-2009 10. Instead of Rs. 8,96,16,915/- it was considered as Rs. 8,91,99,739/-. However the service tax credit amounts reflected against each of the services were correctly considered. Hence for the purpose of deciding this notice, I have considered the total amount of Rs. 67,00,80,012/ - which is a correct value. The difference is of very very small amount, therefore, I am considering the higher amount of CENVAT credit in order to provide correct calculations and to work out various amounts in proper manner. 4.6. Benefit of Rule 6(5) Rule 6(5) of CENVAT Credit....
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....elation to setting up, modernization, 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, activities relating to business, such as accounting, auditing, financing, recruitment and quality control, coaching and training, computer networking, credit rating, share registry, security, business exhibition, legal services inward transportation of inputs or capital goods and outward transportation upto the place of removal; 4.7.2. Definition of 'input services' post 1.4.2011 (subsequent to amendment vide notification No. 3/2011-CE(NT) reads as - "Input service" means any service, - (i) used by a provider of Output service for providing an output service; or (ii) used by the 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 , modernization, renovation or repairs of a factory, premises of provider of output service or an office relating to su....
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.... considered as "Input Services". Over a period of time, Courts have taken a view that there should be some nexus between input services and output services. I find that there are services like Event Management service, Fashion Designing, Mandap Keepers, Photography, Sound Recording, Pandal and Shamiana, Club or Association Service, Credit Card Service, Club Membership Service, which do not have any direct linkage with the output service of the Noticee. Becoming a Member of the Club or Organizing function where Mandap Keeper service have used has no direct relationship with the brand promotion activity of the Noticee. 4.7.6. I also find that there are certain Construction related services which also cannot be said to have any nexus with the output services. I further find that there are certain services, as detailed above like Works Contract Service, which have been excluded from the definition of Input services but still they have taken the CENVAT credit after 1st April, 2011. At this stage, I also mentioned that from 1st April, 2011, the definition 'Input Service', was restricted by deleting the term activities relating to business. Therefore, many of the services which....
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....89842 7725 138484 4890 176473 617414 categor y (i)& (ii) 1 7 Constructio n of complex 0 0 0 0 9003 9003 categor y (iii) 1 8 Credit Card 0 845 0 0 0 845 categor y-(i) 1 9 Membershi p Club 945763 91179 0 5695 0 1042637 categor y (ii) 2 0 rent a cab 0 33319 175901 107862 72337 389419 categor y-(ii) 2 1 Works Contract 172462 0 0 0 0 72462 categor y (iii) Total inadmissibl e credit 8111842 6138353 3464266 114586 2 165388 4 2051420 7 Based upon the above discussion, I ordered for disallowing the CENVAT credit on the below mentioned 21 services totaling to Rs.2,05,14,207/-. 4.7.7. The Noticee in his reply dated 3.2.2015 has provided exact nature of some of the input services to show how there are used for providing their output service of brand promotion. However, I find that out of the 21 services identified by me as not eligible for CENVAT credit, they had given exact nature of only two services namely, Event Management Service and Mandap K....
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.... 6A of the Service Tax Rules, 1994 I have examined the Profit & Loss account of TSL to find out the nature of various incomes earned by them. It would be necessary to determine whether any particular income is an income on account of provision of 'service, whether taxable service or exempted service. This determination would be necessary to work out reversal of CENVAT credit if at all required because of use of common input services in the taxable or exempted service. I am discussing the major source of income as revealed from the Profit & Loss account of the Noticee. A chart of the major income is also given in para 4.9 below. 4.8.1. Dividend Income: The TSL has invested in the shares of Tata Group of Companies and it earns dividend from this investment. The question is whether the dividend income can be considered as a service income or not. In my view, the dividend income cannot be considered as service income because it is in the nature of share of profit earned by the owners of an organization. The Shareholders are like owners and dividend is like their share of profit. On this account, dividend income cannot be considered as arising from provision of any service.....
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....ween purchase and sale price or 1% of the purchase price, whichever is more. Since, I am considering the Explanation inserted with effect from 1st April, 2011 as applicable for the past period, I should be reasonable enough to allow the benefit of valuation also as provided in law from 1.4.2011 for the past period. Therefore, I adopt the methodology provided under above mentioned Explanation for working out the value of exempted service for sale of Shares and Securities. For the purpose of calculation of the value of exempted service in case of sale of share or securities, the details, namely, purchase cost of the shares and sale proceeds was called from the Noticee and vide their letter dated 21st August, 2015 they provided these details. Based upon these details, the value of 'exempted service' i.e. service value of the trading activity has been worked out which is given below: (Amount in Rs. For col 2 to 5) FY- 2008-09 BOOKVALUE OF SHARE PROFIT/LOSS ON SALE SALE PROCEEDS 1% of purchase Value of Exempted d Service Rs. in Crs.* TCS 24233313 8925756667 8901523354 242333 890.15 TATA TELE 3621172720 16508911860 12....
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....HERAPEUTICS LTD 97597200 100792649 3195449 975972 0.32 COMUTATIONAL RESEARCH LAB 1715000000 163920058 4 -75799416 1715000 0 1.71 EWART MAURITIUS 3255170 840551 -2414619 32552 0 TOTAL 2455961116 3469998828 1014037712 24559611 111 *[Value of Exempted service in Col.(6) has been calculated based upon the higher of Col.(4) and col.(5)]. On the basis of above work sheet, the values of exempted services were considered for the purpose of arriving at the allowable quantum of Cenvat credit under Rule 6(3A) of CCR, as discussed in the para 4.9 and 4.10 below. 4.8.3. Miscellaneous Receipts: The details of these receipts have not been made available during the adjudication proceedings inspite of request made by us. Hence I am considering the income from the Misc. Receipts as income from the 'exempted services' for the purpose of quantification of the proportionate Cenvat credit attributable to the exempted services. 4.8.4. Income from long term investment in Immovable Property: This represents profit made on sale of immovable property. Trading of immovable property is not a service. E....
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.... S) Tot al inc om e fro m tax abl e ser vic es (3 +8 ) Valu e of exe mpt ed serv ice (4+ 5) Tot al val ve of ser vic e inc om e (1 2+ 13 ) % of tax abl e ser vic e 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 20 08 - 09 175 5.3 291. 2 2185 .0 8.0 4.6 0.0 0.0 0.0 0. 0 0.0 29 1.2 219 3.0 24 84. 2 11. 7 20 09 - 10 209 6.7 290. 0 398. 0 6.0 6.0 0.0 2.0 9.1 3. 8 0.0 29 2.1 404 .0 69 6.1 42. 0 20 10 - 11 346 4.8 319. 8 631. 0 29. 0 6.4 0.2 1.3 0.0 0. 0 0.0 32 1.1 660 .0 98 1.2 32. 7 20 11 - 12 340 3.1 383. 4 708. 0 13. 0 5.7 5.4 0.0 0.0 0. 0 20 7.4 38 3.4 721 .0 11 04. 3 34. 7 20 12 - 13 466 9.8 378. 3 111. 0 11. 4 5.2 4.9 0.0 73. 1 0. 0 50 8.4 37 8.3 122 .4 50 0.7 75. 6 [NS- Not a service. TS-Taxable service ES-Exempted serv....
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....80999 301260 1925980 2 3 Video Tape Services 70860 34426 3 20117 44352 8181 487773 2 4 Bank & Financial Services 214124 29124 6 0 0 0 505370 2 5 Business Support Services 422686 40 23890 047 22338 368 1886678 7 9786127 117149969 2 6 Interior Decorator 24039 47297 55426 22701 74943 224406 2 7 Internet Café 182539 18402 89200 223910 134783 648834 2 8 Insurance Auxiliary Service 931079 84029 8 93934 9 1074153 106721 3891600 2 9 Management Consultant's Services 121645 43 53956 894 66121437 3 0 Management, Maintenance & Repair 112282 2 26901 09 3812931 3 1 Business Exhibition Services 2379 74749 40423 25959 27598 171108 3 2 Commercial Training & Coaching 378290 8 28208 87 78836 2 2598587 31827 10022571 3 3 Convention Services 123473 1 18196 42 84465 5 675960 12303....
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.... will increase the value of shares of TATA group and assessee will definitely gain from the said value which is reflected in the profit made by them. The trading of share is an "Exempted Service", hence services of M/s. Vaishnavi Corporate Communication Private Limited needs to be considered as common input services used for provision of taxable and exempted service and as per rule 6(3), proportionate reversal of credit is necessary. Similarly, the expenses incurred in advertising agency are also meant for advertising TATA brand. The logic given for service provided by 'Vaishnavi' would be equally applicable for this service also. Other services like Chartered Accountant services or telephone services or security services etc., can be said to be used for providing brand promotion services as well as it will help in provision of other exempted service like service of trading shares. Same logic would be applicable for other services also. Therefore, I do not agree with the Noticee's contention that these services are exclusively used for brand promotion services. To repeat, the telephones have been used for carrying out business of TATA Sons as a whole and it cannot be sa....
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....rms of Rule 14 (1) of the CENVAT Credit Rules, 2004 read with proviso to Section 73 (1) of the Finance Act, 1994 and for imposition of penalty under Rule 15 (3) and 15 (4) Commissioner has held as follows: "Invocation of Extended period 4.12 The Noticee has raised a point that, they have been providing lot of information to the Department from time to time and therefore suppression cannot be allowed in the present case, I have gone through the correspondence submitted by them. They have furnished Annual Reports, details of CENVAT credit attributable to exempted services, information for preparing the profile of the company, 3CD Income Tax Audit report etc. Submitting the Balance Sheet or 3CD report or reversal of credit information does not mean that department was aware of availing of CENVAT credit of various services which are used in taxable as well as non-taxable services. If the information is given by a well reputed group like of Noticee, department cannot believe that those information would be incomplete. Simply giving copy of the Balance Sheet does not mean that all relevant information has been provided to the department. I could have accepted their view, if any inq....
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.... period of limitation. In our view the demand to this extent cannot be sustained and needs to be set aside. Computational Errors 4.7 As regards computational error as stated by the revenue in the appeal the issue do not involve any specific question of law to be agitated upon. Appellant have also pointed out certain computational errors in calculating the amounts to be confirmed. These are matter of factual verification for which we would remand the matter back to the original authority for re- computation of demand if any in accordance with the principles of law determined by us in this order. Merits of the Case: 4.8 The demand in the present case has been made by referring to the incomes indicated by the appellant in their book of accounts. The case against the appellant is that substantial portion of the business income earned by the appellant is from trading of securities, which is exempt from payment of service tax. Even if it is held that appellants were trading in securities, then also for the benefit of Rule 6 (3D)(d) of CCR will have to be allowed, and impugned order cannot be faulted to that extent. The department appeal in this respect do not hold any merits.....
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.... of any exempted services. Even otherwise, since tax was paid on the entire premium recovered towards the service of managing investment in approved securities, appellant cannot be said to be rendering any exempted services. The term "Exempted Services" has been defined in Rule 2(E) of CENVAT Credit Rules, 2004, which reads as under: "exempted services" means taxable services which are exempt from the whole of the service tax leviable thereon, and includes services on which no service tax is leviable under section 66 of the Finance Act (and taxable services whose part of value is exempted on the condition that no credit of inputs and input services, used for providing such taxable service, shall be taken. Explanation - For the removal of doubts, it is hereby clarified that "exempted services" includes trading)" 12. It can be seen from the above definition that in order to be termed as "Exempted Services", the following is required: (i) Taxable service which is exempted from whole of service tax leviable thereon or (ii) Service, on which no service tax is leviable under section 66(B) of Finance Act; or (iii) Taxable service whose part is exempted on the condition t....
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....from the SEBI. There is a restriction on the right to transfer unit and the appellant cannot transfer units to any other person. Further I find that the appellant cannot be termed as "service provider" because he only makes an investment in the mutual fund and earn profit from it which is shown in the Books of Accounts under the head "other income". Hence the question of invoking Rule 6 does not arise and I am of the view that Department has wrongly invoked the provisions of Rule 6(3) demanding the reversal of credit on the exempted services. I also find that substantial demand is time-barred as during the audit, the Department entertained the view that the appellant is engaged in providing the exempted services and consequently issued the show-cause notice. The appellant has been filing the returns under the taxable service of 'Commercial Training and Coaching and has provided all the records to the Department during the course of investigation and has not suppressed any material fact from the Department and in view of the various decisions relied upon by the appellant, extended period cannot be invoked where the Revenue's case is based on Balance Sheet and income return a....
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....pplicable. In view of my discussion above, I am of the considered view that impugned order is not sustainable in law and therefore I set aside the same by allowing the appeal of the appellant with consequential relief, if any." In view of the decisions as above we are inclined to hold against the applicability of Rule 6 (3) by treating the 34 services as has been held by the Commissioner as common input services for providing the exempted and taxable services of brand promotion. In our view the present case is not for determination of common input services, but revenue needs to identify those services which have been exclusively used for providing the taxable service and those which have been used for management of investments. Thus for reconsideration of the common inputs used for providing the exempted and taxable service as determined in para 4.8 of the impugned order the matter needs to be remanded back to the original authority. Authorized representative has relied upon certain decisions rendered by the tribunal in case of trading f goods wherein it has been held that proportionate reversal as per the rule 6 (3) should be applicable to the case of trading of goods during th....
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....ailed by the appellant is in respect of the Service Tax paid by various service providers who had rendered the services of advise, procedural issue as to raising the finance by pledging of the shares on behalf of the appellant for borrowing from IDFC Ltd.; advisory service provided in relation to divestment of stakes in Indus Ind Telecom Network Ltd.; advisory services provided for acquisition of shares in a company; advisory services provider for disinvestment of stakes owned by the appellant and its subsidiaries in various entities and syndication fee for arranging loan of Rs. 200 crores to appellant. 5.4 It can be seen from the above reproduced services which were received by the appellant were in respect of raising of finance for the expansion of the business of the appellant. This specific plea taken by the appellant before adjudicating authority has not been controverted in the impugned order which would mean that the adjudicating authority has accepted that the appellant had embarked upon expansion of the business. It is to be recorded that for expanding any business, there is always requirement of working capital which needs to be raised by the assessee and in this case,....
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....h is paid on (i) any input or capital goods received in the factory of manufacturer of the final product; and (ii) any input service received by the manufacturer of the final product. The subordinate legislation in the present case makes a distinction between inputs or capital goods on the one hand and input services on the other. Clause (i) above provides that the Service Tax should be paid on any input or capital goods received in the factory of manufacture of the final product. Such a restriction, however, is not imposed in regard to input services since the only stipulation in clause (ii) is that the input services should be received by the manufacturer of the final product. Hence, even as a matter of first principle on a plain and literal construction of Rule 3(1) the Tribunal was not justified in holding that the appellant would not be entitled to avail of Cenvat credit in respect of services utilized in relation to ammonia storage tanks on the ground that they were situated outside the factory of production. The definition of the expression 'input service' covers any services used by the manufacturer, whether directly or indirectly, in or in relation to the manufacture of fi....
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....and use of ammonia is an intrinsic part of that process". In the case of Ultratech Cement : "27. The definition of "input service" as per Rule 2(1) of 2004 Rules (insofar as it relates to the manufacture of final product is concerned), consists of three categories of services. The first category, covers services which are directly or indirectly used in or in relation to the manufacture of final products. The second category, covers the services which are used for clearance of the final products up to the place of removal. The third category, includes services namely; (a) Services used in relation to setting up, modernization, renovation or repairs of a factory, (b) Services used in an office relating to such factory, (c) Services like advertisement or sales promotion, market research, storage upto the place of removal, procurement of inputs, (d) Activities relating to business such as, accounting, auditing, financing, recruitment and quality control, coaching and training, computer networking, credit relating, share registry and security, inward transportation of inputs or capital goods and outward transportation upto the place of removal. Thus, the definition ....