TaxTMI 
TaxTMI 
2023 (1) TMI 542
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....espect of input services availed by its Zonal Training Centre (ZTC), Zonal Office (ZO) and Zonal Audit Office (ZAO) in terms of Rule 2(l) of Cenvat Credit Rules, 2004 and whether the services received by Zonal Training Centre, Zonal Office and Zonal Audit Office falls under the definition of 'input service' as provided by Rule 2(l) ibid? 3. It is the case of the department that the appellant, who is engaged in providing 'banking and financial services', has wrongly availed the Cenvat credit of service tax paid under reverse charge mechanism on services i.e. legal consultancy service, security/ detective agency service, recovery agent service and GTA service and service tax paid on telephone bills, availed at their Zonal Training Centre (ZT....
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....se had obtained centralized service tax registration and these three wings in issue, are assisting the appellant in its day to day operation; that the appellant is discharging its service tax liability on the total value of taxable services provided by all the premises covered under the centralized registration after utilizing the Cenvat credit of the input services received at these offices; that although these offices are not providing any taxable services on their own but they are assisting the appellant in providing its output services efficiently; that had these offices been there in the same premises as that of the appellant then the department would have allowed the Cenvat credit of input services availed by these offices. So far as ....
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....ncluding the synopsis & case laws cited by the respective sides. Admittedly the centralized registration has been obtained by the appellant in terms of Rule 4(2) of Service Tax Rules, 1994. The said rule provides that if a person is providing any taxable service and using one or more separate premises, which are assisting directly or indirectly in providing such taxable services and has centralized billing/accounting system, then the service tax registration for such separate premises can be obtained under the centralized service tax registration. This is irrespective of the fact that such other separate premises are providing any taxable service on their own or not. It is the case of the appellant that these Zonal Training Centre (ZTC), Zo....
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....ppellant and under the proper control and supervision of the appellant. They are not separate entity. For example Zonal Training Centre is engaged in providing training to the employee of the appellant, which is essential for the smooth and effective functioning of the appellant whereas, Zonal Audit Office is managing the internal audit function of the appellant. So far as Zonal Office is concerned, it is providing administrative assistance/ support to the appellant and its circle offices. It is the case of the appellant that they have paid service tax on the value of the taxable services provided by these offices. So far as the observation of the lower authorities are concerned that for availing Cenvat credit of service received it is requ....