TMI Blog2019 (3) TMI 667X X X X Extracts X X X X X X X X Extracts X X X X ..... ords ‘in relation to manufacture’ have been used to widen and explain the scope, meaning and content of the definition and applying the same ratio, CENVAT credit of service tax paid on input services is admissible so far as input services have been used directly or in directly, in or in relation to the manufacture of final product even if the term setting up has been deleted from the inclusive portion of the definition. Also, in the case of Birla Corporation Ltd. vs. Commissioner [2013 (11) TMI 987 - CESTAT NEW DELHI], CENVAT credit on erection, commissioning and installation services have been allowed. Credit allowed - appeal allowed - decided in favor of appellant. - E/20966/2018-SM - Final Order No. 20251/2019 - Dated:- 11-3-2019 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... original authority confirmed the demand of ₹ 30,24,390/- for the period April 2011 to September 2013 along with interest and also imposed equal penalty. Aggrieved by the said order, appellant filed appeal before the Commissioner (A), who rejected the same. 3. Heard both the parties and perused the records. 4. Learned counsel for the appellant submitted that the impugned order is not sustainable in law as the same has been passed without properly appreciating the definition of input service after the amendment of the same with effect from 1.4.2011. He further submitted that the services were utilized for erection, commissioning and installation of sugar manufacturing machinery/co-generation plant and none of the impugned servi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... vailment of the CENVAT credit in ER-1 Returns and therefore, according to the learned counsel substantial demand is barred by limitation as there is no suppression of fact on the part of the appellant with intent to evade duty. In support of his submission, he relied upon the following decisions: Uni Abex Alloy Products vs. CCE: 2019 (2) TMI 569 Grindwell Norton Ltd. vs. CCE: 2018 (1) TMI 715 Hindustan Coca Cola Beverages Pvt. Ltd. vs. CCE: 2017 (6) TMI 846 Orient Cement Ltd. vs. CCE: 2017 (51) STR 459 Musaddilal Projects Ltd. vs. CCE: 2017 (4) GSTL 401 Sai Life Sciences Ltd. vs. CCE: 2017 (51) STR 55 Idea Cellular vs. CCE: 2016 (3) TMI 1117 5. On the other hand, the learned AR ..... X X X X Extracts X X X X X X X X Extracts X X X X
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