2024 (6) TMI 679

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....hri Gopal Mundra a/w Shri Parth Parekh, Advocates for the Appellant Shri Mahesh Patil, Authorized Representative for the Respondent ORDER Denial of Cenvat Credit of service tax paid on various services is the subject matter of the present dispute. These disputed services are Consultancy Service, Hotel Service, Erection, Commissioning and Installation, Technical Testing and Inspection, Tec....

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....s and perused the case records. 3. The definition of input service, prior to its amendment w.e.f. 01.04.2011 provided the phrase "used in relation to setting up, modernization, renovation or repairs of a factory" in the inclusive part contained therein. The said definition was amended vide Notification No.3/2011 dated 01.03.2011 (w.e.f. 01.04.2011). The effect of such amendment was that the phr....

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....deration of the disputed services used/utilised by the appellants as listed out in paragraph 1 above, we find that such services were not falling under the exclusion clause provided under Rule 2(l)(A) ibid. Since, the disputed services were not specifically falling under the excluded category and were used in relation to manufacture of the final products, in our considered view, denial of Cenvat C....

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....rvice is further enlarged with the expression whether directly or indirectly used in the definition of input service. Thus, there are: a) Actual manufacture; b) Processes incidental or ancillary to manufacture which are also manufacture; c) Activities directly in relation to manufacture (i.e., in relation to 'a' and 'b' above); d) Activities indirectly in relation to manufacture (i.e., in relation....