2024 (11) TMI 1582

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....ee, duly registered under the Companies Act, 1956. ABMCPL was incorporated to provide common corporate facilities and resources to group companies to enable them to optimize the benefit of specification and achieve economies of scale. The appellant was a part of the group company of ABMCPL. Therefore, during the period under consideration, the appellant received various common business support services from ABMCPL. The common facilities provided by ABMCPL were in the areas of human resources, information technology, business strategies, marketing, legal support, accounting support, knowledge and training etc. At the end of each month, the expenses incurred by ABMCPL to provide such common facilities were apportioned and charged to the group....

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....o as the 'impugned orders'), wherein the adjudged demands were confirmed / upheld by the department. Feeling aggrieved with the above impugned orders, the appellants have preferred these appeals before the Tribunal. 2. Heard both sides and examined the case records. 3. We have perused the sample copy of invoices issued by M/s ABMCPL to the appellants. The invoices were issued on monthly basis, with the narration 'being Business Support expenses incurred on your behalf for the month as per attached details'. It is an admitted fact on record that M/s ABMCPL is registered with the service tax department for providing the taxable service under the category of business support services. The service tax paid on provision of such service was....

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....n provide various other services, which can also be considered as input service for a manufacturer of excisable goods. The said definition clause, effective upto 13.03.2011, had provided that "activities relating to business", should also be considered as input service. Rule 2 (l) ibid, was amended w.e.f., 01.04.2011, providing certain excluded category of services, which shall not be considered as input service. In the case in hand, for the period April 2007 to March 2011, the appellants had paid for the services provided by M/s ABMCPL and accounted for such payment as expenses in their books of accounts. Thus, it can be said that such expenses incurred were in context with accomplishing the purpose or object of the business. With regard t....