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Service Tax - Case Laws
Showing 81 to 100 of 111 Records
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2016 (7) TMI 424
Refund - Excess payment of service tax - Unjust enrichment - Acceptance of credit notes - recipients were entitled to cenvat credit or not - Commissioner of Central Excise (Appeals), Mumbai-I that has credited the refund of service tax claimed by the appellant to the Consumer Welfare Fund. - Held that:- Credit notes do not exist as inactive exhibits; the financial adjustment is manifested as entries in journals and ledger to impact the consideration made over and received for any goods supplied or service rendered. With credit notes being a conventional method of reflecting the change in consideration, and its authenticity not having been refuted, reliance has necessarily to be placed on the net effect that it has on the taxable transaction. Reversal of 'brokerage' carries with it the reversal of tax collected along with the excess 'brokerage.' We, therefore, need merely to ascertain if any of the cited decision prevent acceptance of credit note.
The tax is structured entirely on the existence of documentation and alienation of credit or debit notes from this documentary flow by conferment of finality to one document that serves the cause of Revenue is not consistent with the basis of taxation in section 67 of Finance Act, 1994 viz. consideration for services rendered. The decisions cited by Revenue do not, therefore, serve to support the findings in the impugned order.
The original authority had not sought to reject the claim for refund on the ground of lack of evidence that CENVAT credit, that the recipients were entitled to, had been reversed. Therefore, invoking of this ground in the impugned order is tantamount to travelling beyond the show cause notice.
The manner in which credit is administered is not within the obligatory supervision of the provider of service or supplier of goods. The system is 'honor-driven' by predicating the availment on supporting documentation with the onus of reversals placed squarely on the recipient. The issuance of credit note automatically curtails the entitlement and their existence suffices to enforce reversal in the course of scrutiny of returns or audit. In view of implicit reduction of entitlement to credit, with ample recourse for recovery under the Rules, assumption of having passed on the burden of tax fails to be a valid conjecture. The provisions of section 11B of Central Excise Act, 1944 cannot be stretched to fasten what is, essentially, the monitorial responsibility of tax authorities on to an assessee.
The impugned order has erred in crediting the excess tax collected in the Consumer Welfare Fund - Refund allowed.
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2016 (7) TMI 423
Validity of order of Settlement Commission rejecting their settlement application with respect to service tax liability - Held that:- Viewed from any angle, the Settlement Commission has erred in rejecting the petitioner’s application for settlement dated 25.11.2013, by its order dated 14.11.2014, on the ground that the said application was barred by Section 32-(O)(1)(i) of the Act. As noted hereinabove the Explanation to Section 32-O(1)(i) does not have retrospective effect and, consequently, the petitioner’s application dated 25.11.2013 would be barred under Section 32-(O)(1)(i) of the Act only if either of the two earlier settlement applications, submitted by the assesee, had suffered imposition of penalty for concealment of duty liability before the Settlement Commission itself.
We see no reason, however, to undertake a minute scrutiny of the earlier orders passed by the Settlement Commission, on 30.10.2013 and 06.11.2013, to determine whether penalty was imposed on the petitioner for concealment of duty liability before the Settlement Commission itself. The order dated 14.11.2014, impugned in W.P. No.38658 of 2015, is set aside and the matter is remanded to the Settlement Commission for its consideration afresh in the light of the law declared and the observations made in this judgement. - Decided in favor of petitioner.
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2016 (7) TMI 365
Waiver of pre-deposit - Maintainability of writ petition against the order confirming the demand of service tax with interest and penalty - alternative appellate remedy - the submission of the learned counsel for the petitioner is that the petitioner should be permitted to go before the Tribunal with a direction to the Tribunal to take up the stay application, thereby bypassing the pre-deposit condition, which has been made mandatory with effect from 6.8.2014.
Held that:- this Court is of the view that the relief sought for to direct the petitioner to approach the Tribunal and file a stay application with a further direction to the Tribunal to hear the same thereby waiving the condition of pre-deposit of 7.5%, cannot be acceded to. - Accordingly, the writ petition is dismissed as not maintainable. - Decided against the petitioner.
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2016 (7) TMI 364
Cenvat Credit - input services for providing output services of management, Maintenance and Repair service and also Consulting Engineer’s Service - credit was availed on Scheme operator’s service, Outdoor Caterer’s service and Group Insurance Service for the period October, 2009 to September, 2010 - Held that:- the issue is covered by the judgement of the Karnataka High Court in the case of CCE, Bangalore Vs. Bell Ceramics Ltd. [2011 (9) TMI 792 - KARNATAKA HIGH COURT] - Credit allowed - Decided in favor of assessee.
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2016 (7) TMI 363
Cenvat Credit - Eligibility of Input services received at Head Office - ISD - Jurisdiction - The adjudicating authority confirmed the demand on the ground that appellant is not eligible to avail cenvat credit on the services; the ISD has distributed services which are not in accordance with Rule 7 of the Cenvat Credit Rules, 2004. - Held that:- the question of jurisdiction as raised by the ld. Consultant is non-starter as the adjudicating authority has recorded that they are disputing only the eligibility of cenvat credit at the factory level in respect of services. There is no dispute at ISD level on availment of cenvat credit.
Services on which cenvat credit sought to be demanded is eligible to be availed as cenvat credit by the appellant as well as ISD as per various case law cited by the ld.Consultant. In view of this, the finding of the adjudicating authority that appellant is not eligible to avail cenvat credit on those services is incorrect and this finding needs to be set aside.
However, cenvat credit can be availed at Bhiwadi factory shall be as per formula under Rule 7(d) of the Cenvat Credit Rules, 2004. In order to arrive at correct cenvat credit that can be availed by the appellant, the matter is remanded back - Decided partly in favor of assessee.
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2016 (7) TMI 307
Taxability of services provided by the SEZ unit to the DTA unit of the same assessee - principle of mutuality - Maintainability of appeal before the High Court - whether the appeal would lie before the Honble Supreme Court as provided under section 35(L) of the Act? - Demand of service tax with interest and penalty - The assessee opposed such proposal mainly on the ground that one unit of a company cannot provide service to another unit since for providing taxable service, it is necessary that there should be two separate entities.
Held that:- the Special Economic Zones Act was enacted to provide for the establishment, development and management of the Special Economic Zones for the promotion of exports and for matters connected therewith or incidental thereto. - All the statutory provisions indicate separate and artificially created independent existence of a SEZ unit of a company whether it has another unit situated in Domestic Tariff Area or not. In particular, Rule 19(7) of the Special Economic Zones Rules, 2006 while recognising that the same legal entity may have two units, one in SEZ and another in DTA, mandates that the two would have distinct identities with separate books of accounts.
For various purposes, thus a SEZ unit of an enterprise which also has an additional unit in Domestic Tariff Area, therefore, has a distinct identity. Its accounts are separate, its accounting would be separate. This artificial creation of separate accounting of a unit or an industry of a common enterprise or a company, is not a new or unknown phenomena. In number of cases, where Income Tax Act provides profit linked incentives such as deductions under sections 80HHC, 80I, 80IA, 80IB, etc., the industry or unit engaged in such eligible business is treated separate and distinct for the purpose of accounting so that deductions of the assessee out of its eligible business can be separately worked out.
Under the circumstances, in view of statutory scheme noticed in the Finance Act, 1994 and Special Economic Zones Act, 2005, the contention of the respondent company that on the principle of mutuality, the services rendered by its SEZ unit to a Domestic Tariff Area unit, would not be chargeable to service tax, cannot be accepted.
Valuation - free services - Held that:- When the service is provided but no value thereof is charged, there would be no question of collecting service tax. No provision has been brought to our notice in the Finance Act, 1994 under which though the service provider has not charged any value for service, service tax thereon still can be levied on its deemed value, be it market value or fair value. - if the department proceeds on the premise that a certain service though otherwise a taxable service, the service provider did not collect any charge for the same from the service recipient, in our opinion, it would simply not be possible for the authority to collect any service tax on such service.
For such reasons, while therefore, dismissing the Revenue's appeal against the judgement of the Tribunal, on the grounds different from which appealed to the Tribunal, we answer the question clarifying that in the present case, no service tax was leviable since the SEZ unit of respondent assessee had not charged for the services provided to its DTA unit. - Decided against the revenue.
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2016 (7) TMI 306
Challenge to the order passed by the Settlement Commission - The only issue which was not decided in favour of the petitioner is with regard to income from SEZ. However, on a perusal of Paragraph 6.10 of the impugned order, it is seen that the claim for exemption for the income of ₹ 81,10,41,888/- from the SEZ units for the year 2011-12 and 2012-13, the Commissioner has referred to a report submitted on 06.04.2016 and came to a conclusion that petitioner has not furnished the exclusive income at the time of investigation and pointed out that it is not possible to furnish the quantum of taxable income received from SEZ units. - The petitioner's case is that they were never put to notice about such a report and had they been informed about the same, they would have definitely conceded to the claim and also paid tax .
Held that:- On a reading of the impugned order passed by the Settlement Commission, it is evidently clear that this vital opportunity was not granted to the petitioner before the case came to be referred back to the jurisdictional Commissioner for adjudication. The respondents are not in a position to justify the impugned order as procedural error looms large on the face of the impugned proceedings. Therefore, the impugned order to that extent, namely with regard to the income from SEZ, calls for interference. The learned senior counsel appearing for the petitioner informed the Court that after the impugned order was passed and before filing the writ petition, the petitioner has further admitted the liability and paid a sum of ₹ 2,31,12,732/- apart from the payment already made i.e., ₹ 6,10,21,642/-. This aspect of the matter shall also be considered by the Settlement Commission while taking up the case for settlement of issue, viz., Income from SEZ, which has been remanded for consideration.
The writ petition is partly allowed and the impugned order is set aside, to insofar as the findings rendered by the Commissioner under the head Income from SEZ and the matter is remanded to the Settlement Commissioner for fresh consideration.
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2016 (7) TMI 305
Challenge to the show cause notice - Maintainability of writ petition - learned Single Judge dismissed the petition [2015 (4) TMI 1128 - KARNATAKA HIGH COURT] - appellant submitted that the show cause notice issued by first respondent is one without jurisdiction and same cannot be sustained in the eye of law. - Held that:- On perusal of the order passed by the learned Single Judge, we do not find any illegality or material irregularity nor any good ground as such made out by the appellants to consider the reliefs sought in the appeals for the reason that the Writ Petitions filed by the petitioner are dismissed reserving liberty to the petitioner/appellant to file reply or objections to show cause notice within two weeks from the date of receipt of copy of the said order. Further, it emerges that they have filed a reply to the show cause notice before the first respondent. Therefore, we do not find any justification or good ground, as such made out by the appellant to consider the relief sought for by the appellant nor the appellant has made out any good ground to entertain the relief sought in Writ Appeal. - Petition dismissed. - Decided against the assessee.
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2016 (7) TMI 304
Demand of service on Civil Work, Infrastructure Charges paid to TNEB - Denial of cenvat credit - erection and installation of the work of electricity generation system which is a composite contract involving the installation of generator as well as execution of Civil Work carried out by the appellant. - Held that:- Erection service provided was purely a Works Contract Service since that involved Civil Works as well as Electrical Works. Such works carried out before 01.06.2007 shall not be taxable .
So far as Erection Charges is concerned, pertaining to the period 01.04.2008 to 33.03.2009, it may be stated that, that shall be liable to tax and what that is done by the learned adjudicating authority is proper.
The Infrastructure Charges paid to TNEB and incurred by the appellant directly as well as reimbursed to it, is not in relation to any services provided by the appellant to its clients. Therefore, in the absence of any taxing entry to tax such receipts the appellant is not liable to service tax thereon.
The Cenvat credit denied pertains to the input credit taken by the appellant for use thereof in manufacture of the generators. The generator not being liable to duty by virtue of exemption, appellant is liable to pay back entire credit taken to the State with interest. It is made clear that utilisation of the credit shall be calculated from the date of utilisation thereof and interest, if any, payable shall be calculated from that date till the period that was paid back to State.
Accordingly appellant is liable to penalty. However considering the facts and circumstances of the case, to reduce the dispute, it would be proper to direct the appellant to deposit 25% of the demand of duty on this count of ineligible credit issue pertaining to the period 01.10.2006 to 31.03.2008.
Decided partly in favor of assessee.
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2016 (7) TMI 303
Levy of penalty - Non payment of service tax at the time of filing of the ST-3 returns - The amount was paid subsequent to filing of service tax returns but before the issuance of the Show cause notice. - Held that:- the entire service tax and interest has been discharged by the appellant assesse before issuance of Show cause notice. - Levy of penalty waived invoking the provisions of Section 80 - Decided in favor of assessee.
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2016 (7) TMI 237
Challenge to the Show Cause Notice (SCN) - Maintainability of writ petition - Business Auxiliary services (BAS) - The petitioner is a cricketer and is a former captain of the Indian Cricket Team - Amount received for brand endorsement/brand promotion - amounts received for writing articles in sports magazines as well as fee received for anchoring TV shows on Zee Bangla. - extended period of limitation - allegation of suppression of facts - Held that:- if it is finally decided that the extended period of limitation was wrongly invoked by the authority in issuing the impugned show cause notice, the logical conclusion that would follow is that the show cause notice was issued without jurisdiction.
Since the petitioner has challenged the jurisdiction of the authority to issue the impugned show cause notice, in my view, the writ petition cannot be rejected at the threshold. Whether or not the petitioner will ultimately succeed on merits is a different question altogether. However, in my opinion, it cannot be said that the writ petition is not maintainable at all and should not be entertained for adjudication. - the preliminary issue of maintainability of the writ petition is decided in favour of the petitioner.
Invocation of extended period of limitation in the SCN - Held that:- the petitioner was prompt and diligent in responding to all the notices issued by the Department and in his replies, the petitioner clearly explained the nature and scope of his activities. Subsequently, copies of contracts entered into by the petitioner with the corporate entities were also made available to the Department. In my view, there was full and sufficient disclosure of the nature of the petitioner’s activities to the Department and it cannot be said that the petitioner suppressed material facts to deceive the Department with intent to evade payment of service tax.
It is also be noted that it is stated in the last paragraph of the impugned show cause notice that the same is ‘based on records made available’. On a plain reading this means that the notice was issued on the basis of records and materials submitted by the petitioner. Hence, there does not seem to be any basis in the Department’s contention that the petitioner suppressed material facts with intent to evade payment of service tax. Suppression of fact in the context of this case can only mean non-disclosure of correct information deliberately to evade payment of service tax.
The impugned show cause notice is hopelessly barred by limitation. There was no ground or justification whatsoever for issuing such notice by invoking the extended period of limitation.
Demand of service tax under Business Auxiliary Services (BAS) - Held that:- It was not the intention of the legislature that any and every kind of activity which can loosely be termed as ‘Business’ would attract service tax. It being a taxing provision, the same must be construed strictly and any benefit of doubt in the matter of interpretation of the provision must go in favour of the assessee.
Writing articles for newspapers or sports magazines or for any other form of media cannot by any stretch of imagination be said to be amounting to rendering business auxiliary service within the meaning of Sec. 65(19) or business support service under Sec. 65(104c) of the Finance Act, 1994.
For similar reasons, the remuneration received by the petitioner for anchoring TV shows cannot be brought within the service tax net. Television shows are meant for entertainment of the viewers. In contemporary world watching television is a primary form of recreation. It would be absurd to say that anchoring TV shows amounts to rendering business auxiliary service or business support service.
Regarding, brand endorsement - Held that:- by amendment of the Finance, Act, 1994, a new taxable service category of ‘Brand Promotion’ was introduced with effect from 1 July, 2010 - Since brand endorsement was not a taxable service during the period of time for which the tax demand has been raised, such demand cannot be sustained. Such service rendered by the petitioner could not be taxed under the head of business auxiliary service as has been sought to be done.
As regards the remuneration received by the petitioner for playing IPL cricket, in my opinion, the service tax demand raised on such amount under the head of ‘Business Support Service’, is also not legally tenable. - The petitioner was under full control of the franchisee and had to act in the manner instructed by the franchisee. The apparel that he had to wear was team clothing and the same could not exhibit any badge, logo, mark, trade name etc.. The petitioner was not providing any service as an independent individual worker. His status was that of an employee rather than an independent worker or contractor or consultant. In my opinion, it cannot be said that the petitioner was rendering any service which could be classified as business support service. He was simply a purchased member of a team serving and performing under KKR and was not providing any service to KKR as an individual.
Validity of circular / clarifications issued by the CBEC - Held that:- if such circulars/instructions/clarifications are contrary to or inconsistent with the statutory provision in question or seek to create a liability which the statute does not contemplate, such circular/instruction is liable to be struck down. A misconceived and legally untenable interpretation of a statutory provision and/or an erroneous understanding thereof, which if applied by the quasi-judicial authorities will unduly prejudice the citizens of the country, cannot be allowed to stand.
The remuneration received by the petitioner from the IPL franchisee could not be taxed under business support service.
The show cause notice impugned in this petition is without jurisdiction as being time barred. The demand made in the show cause notice is barred by limitation. - Show cause notice quashed - Decided in favor of assessee / petitioner.
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2016 (7) TMI 236
Cenvat Credit - service tax credit on the input services attributable to trading sales - Though the petitioner had challenged this order by filing the writ petition, the petitioner has paid the entire amount without prejudice to their rights. - The petitioner pleads that the petitioner may be permitted to file an appeal against the impugned order before the Commissioner (Appeals). Admittedly, the period of limitation stipulated for filing the appeal has already over.
Held that:- considering the peculiar facts and circumstances of the case, the Writ Petition is disposed of, giving liberty to the petitioner to file an appeal before the Commissioner (Appeals) and if such appeal is filed within a period of 30 days from the date of receipt of a copy of this order, the Commissioner (Appeals) shall entertain the appeal petition without reference to limitation.
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2016 (7) TMI 235
Claim of refund - refund claim was not accompanied by Form A-1 as provided in Notification No-17/2011 ST dated 01-03-2011 - service tax paid on purchase of software license meant for the authorized operations in their SEZ unit - Held that:- The appellant has DTA operation also and if they file such declaration it would be a false declaration. The contention of the appellant that they are not required to file Form A-1 declaration as per the notification and that they may not be forced to file a declaration which is not applicable to them is not without force .
The conditions mentioned in clause (f) (i) and (h) of the notification goes to show that Form A-1 is not to be furnished invariably in all refund application. It has to be furnished wherever applicable i.e when the applicant is carrying exclusively SEZ operations.
The finding in the impugned order that appellant has to furnish Form A-1 is not legal or proper. This finding in the impugned order is set aside. - the appeal is allowed by way of remand with the findings made in regard to the requirement to file Form A-1. - Decided in favor of assessee.
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2016 (7) TMI 158
Waiver of pre-deposit - demand of service tax - undue hardship - Tribunal concluded that the assessee has failed to establish prima facie case and dismissed the said application on the ground that the assessee failed to prove undue hardship and ordered substantial amount of pre-deposit - Section 35-F of the Central Excise Act, 1944 - the main grievance of the assessee is that the assessee is running in loss for the last many years prior to the demand and on the date of demand for payment of duty or service tax. To substantiate the said contention, the assessee produced profit & loss account statements and Balance sheets.
Held that:- The reasoning recorded by the Tribunal to decline the waiver of pre-deposit is based on accounting procedure of the assessee, even otherwise the loan and advances of the assessee is ₹ 11.35 crores besides Sundry Debtors to a tune of ₹ 08.58 crores. The assessee can realise the amount from the Sundry Debtors and loans and advances, and make pre-deposit as required under Section 35-F of the Central Excise Act.
Therefore, the reasoning recorded by the Tribunal to decline waiver of predeposit is in accordance with law for the reason that the assessee himself disclosed the claim for depreciation to a tune of ₹ 6.80 crores, Sundry Debtors to the tune of ₹ 8.58 crores and loans and advances of ₹ 11.35 crores. Even otherwise, the assessee is a partnership firm, the partners are liable to pay statutory dues to the Government. Therefore, the order of the Tribunal does not indicate that the assessee can sell away the assets and make predeposit.
On an overall consideration of the material on record, the assessee possessed sufficient means to comply with the requirement of Section 35-F of the Central Excise Act and that the assessee would not be put to financial hardship for compliance of the same. - No relief - Writ Petition shall stand dismissed - Decided against the petitioner.
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2016 (7) TMI 157
Levy of service tax on import of services under reverse charge mechanism - for the period August 2002 to December, 2004 - Held that:- This issue was settled by Bombay High Court judgement in the case of Indian National Ship-Owners Association vs. UOI [2008 (12) TMI 41 - BOMBAY HIGH COURT]. - In view of the above Service Tax on Reverse Charge Mechanism for the services received from abroad cannot be charged for the period prior to 18.04.2006. - Decided in favor of assessee.
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2016 (7) TMI 156
Cenvat Credit - original duty payment document / invoices were lost / destroyed in the fire - department contended that respondent were not having original input invoices to be produced for verification and the Cenvat credit was availed in respect of non existing invoices - Held that:- even though invoices have been destroyed in fire but if invoices have been recorded in the ledger and books of accounts of the respondent the Cenvat credit can not be denied. Respondent could not have recorded the invoice in the ledger unless physical invoices were available. It is not only the invoice or ledger entry but the respondent might have paid invoice value to the service provider which can also be verified from the books of account. Since this verification have not been conducted by the lower authority matter needs to be remanded to the original authority.
Extended period of limitation - Held that:- Even intimation of fire incidence is of no help to the respondent as from the intimation itself it cannot be said whether the invoices were existing or not therefore if it is proved that invoices were received by the respondent, longer period of demand is correctly invokable. As per my above discussion, I set aside the impugned order and remand the matter to the original adjudicating authority to pass a denovo adjudication order after verification of books of accounts, ledger and payment particulars towards such invoices. - Decided partly in favor of revenue.
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2016 (7) TMI 155
Refund of unutilized cenvat credit - Commissioner (Appeals) denied refund disallowing the credit on some input services, observing that the input services do not have nexus with output services. - the period involved is prior to 01-04-2011. - Held that:- As rightly submitted by the consultant appearing for the appellant, the definition of input services during the relevant period had a wide ambit as it included the words activities relating to business . The Tribunal as well as the Courts in numerous judgments have laid that almost all services would be eligible for credit /refund, if such services were needed for the business of the service provider.
Appellants are eligible for refund of service tax paid on the impugned services - further interest on delayed refund shall be granted to the appellant. - Decided in favor of assessee.
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2016 (7) TMI 154
Refund of accumulated input service tax Cenvat credit. - Department denied Cenvat credit mainly stating that the activity of extraction, crushing, grinding, sorting and washing of iron ore undertaken by the assessee does not amount to manufacture under Section 2(f) of the Central Excise Act and therefore, no duty is payable under Section 3 of the Central Excise Act and the goods, therefore, cannot be termed as excisable.
Held that:- In this regard, there are number of decisions of the higher Judicial Fora, wherein it has been made clear that wherever exempted products are exported outside India, provisions of Rule 6(6) (v) of the Cenvat Credit Rules, 2004, will be applicable which states that provisions of Rule 6 (1) to (4) will not be applicable for the excisable goods removed without payment of duty after they are cleared for export under bond in terms of the provisions of Rule 2 of the Central Excise Rules.
Eligibility of credit on input services upto the place of removal - Held that:- here exports are on FOB basis, place of removal is port and not factory gate. Therefore, in the present case, M/s MSPL Ltd. are entitled to the Cenvat credit for all the input services for bringing the goods upto the port of shipment.
Revenue's appeal dismissed - Assessee's appeals accepted - Decided in favor of assessee.
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2016 (7) TMI 131
Recovery of tax u/s 87 from successor of deceased proprietor - SCN was issued to the deceased but could not be adjudicated during his life time - garnishee notices - Validity of decision of learned Single Judge of this Court quashing the recovery notice - Held that:- we are not impressed by the submission of the learned Counsel for the appellants that the power under Section 87 of the Finance Act is independent and irrespective of the procedure under Section 73 nor can we accept the contention that when the power under Section 87 of the Finance Act is to be invoked, no procedure under Section 73 is to be undertaken. If we entertain the contention, the resultant situation would be that the power under Section 87 of the Finance Act would be without an adjudication mechanism under Section 73 of the Finance Act which is neither conceived by the legislature nor can be the accepted position.
In view of the above, read with the reasons recorded by the learned Single Judge, we do not find any case made out for interference. - Decided against the Revenue.
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2016 (7) TMI 130
Restoration of appeal - delayed pre-deposit of amount as directed by the tribunal - Validity of order refusing to restore the order which was dismissed for non-compliance of stay order and for want of prosecution - Held that:- we answer the substantial question by holding that in peculiar facts and circumstances of the case, we are of the considered view, that the learned Tribunal was not right in dismissing the appeal for want of prosecution or non-compliance of the interim order for deposit of pre-deposit amount. - Appeal restored before the Tribunal.
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