TaxTMI 
TaxTMI 
2024 (6) TMI 679
X X X X Extracts X X X X
X X X X Extracts X X X X
....ekh, 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, Technical Testing and Analysis, Audit Ser....
X X X X Extracts X X X X
X X X X Extracts X X X X
....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 phrase "setting up of the factory" was replac....
X X X X Extracts X X X X
X X X X Extracts X X X X
....sed 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 Credit of service tax paid on those services ....
X X X X Extracts X X X X
X X X X Extracts X X X X
....er 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 to 'a' and 'b' above); 22. All four of the abov....