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Supreme Court of India 2018-02-01 allowed

Commissioner of Central Excise Service Tax vs Ultra Tech Cement Ltd

Bench: 2 — A.K. Sikri

In Brief

UltraTech Cement claimed Cenvat Credit on service tax paid for transporting finished cement from its factory to customer premises. The Central Excise authorities rejected this claim, arguing that such outward transport beyond the factory gate is not an "input service" eligible for credit. After conflicting decisions in lower tribunals, the Supreme Court held that the amended Cenvat Credit Rules defining input service as covering transport "upto" (not "from") the place of removal restricts credit to the factory exit point only. Post-removal transport, being distinct from manufacture, cannot qualify as input service. The appeal was therefore allowed, restoring the original order denying the credit.

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Excise Law Service Tax Cenvat Credit Input Service Goods Transport Statutory Interpretation

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