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2025 (6) TMI 1431

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....) for the respondent ORDER This appeal lies against upholding of tax liability of Rs. 21,34,284 on M/s Future Generali India Life Insurance Co Ltd, in order [order-in-appeal no. CKJ/GST/A-I/MUM/16/20-21 dated 5th June 2020] of Commissioner of GST and Central Excise (Appeals - I), Mumbai, which, in disposing off their challenge to order of original authority, has merely taken note of discharge of....

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....VAT Credit Rules, 2004, along with applicable interest, and to penalty of like amount under rule 15 of CENVAT Credit Rules, 2004. 3. Learned Counsel for appellant submitted that the exclusion of taxable territory, under section 60 of Finance Act, 1994 and from section 66B of Finance Act, 1994, was not 'exempted service' intended in CENVAT Credit Rules, 2004. He relied upon the decision of the Tri....

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....could not have been invoked and there was no finding, whatsoever, on any of the ingredients mandated as pre-requisites for fastening the recovery. Learned Counsel also submitted that the entire 'input service' had been taken into account for computation instead of limiting reversal to such as were procured in common. 5. Learned Authorised Representative submitted that the issue of inclusion of se....

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....4. Without going into these allegations, it would appear that the lower authorities had proceeded to invoke rule 14 and rule 15 of CENVAT Credit Rules, 2004 solely on the premise that appellant had not carried out its obligation to reverse the credit available under rule 3 of CENVAT Credit Rules, 2004 despite deployment of procured services on such activities as were excluded from tax liability. I....