2025 (12) TMI 510

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....d operational services rendered by the foreign entity in the years 1998 and 1999. They have also taken CENVAT Credit of Rs.25,82,950/- on account of Service Tax paid for e-auction services received towards sale of scrap from their factory premises. 2. An audit was conducted during December 2009 and the audit pointed out about the ineligibility of CENVAT Credit on these two services vide their Report dated 19.12.2009. 2.1. The appellant filed their reply, defending their stand. 2.2. Subsequently, on 24.09.2013, a Show Cause Notice was issued demanding reversal of these amounts. 2.3. After due process, the ld. adjudicating authority confirmed the demands, along with interest and penalty. 2.4. Being aggrieved, the appellant is b....

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....be allowed, both on merits as well as on account of time-bar. 4. The Ld. Authorized Representative of the Revenue submits that the services were rendered by the overseas party during the period 1998 to 1999 when the same were not liable for any Service Tax, to be paid under reverse charge mechanism; however, the appellant mis-declared the same and obtained one invoice in 2008 and made the payment. He submits that it is not believable that the overseas party would wait for more than nine years to get their payment. Therefore, he justifies the confirmed demand on this score. 4.1. In respect of the e-auction services, he submits that this is unrelated to their manufacturing activity and therefore, justifies the confirmed demand. 5. He....