Cenvat credit on immovable property post completion certificate denied, treated as sale of goods. Credit allowed only on inputs within 1 year.

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....Cenvat credit on immovable property constructed after issuance of completion certificate is not permissible, as transaction is treated as sale of goods, not service. Cenvat credit can be taken only on receipt of inputs and within one year from date of documents. Extended period of limitation rightly invoked as appellant was aware of ineligibility for credit after completion certificate. Imposition of penalty u/s 78 and levy of interest upheld. Appeal dismissed by Appellate Tribunal.....