2025-VIL-181-CESTAT-ALH-CE

CENTRAL EXCISE CESTAT Cases

Central Excise - After-sales service by Authorized Service Centres (ASCs) and Direct Service Centres (DSCs), Cenvat credit on call centre services – Appellant claimed Cenvat credit on the service tax paid to call centres, which facilitate connecting customers to ASCs and DSCs - Department denied the credit holding that call centre service to be a post-manufacturing service and does not qualify under Section 2(l) of the Cenvat Credit Rules, 2004 and do not have a nexus with the manufacturing activity of the appellant - Whether the call centre services are eligible input services under the Cenvat Credit Rules, 2004 – HELD - The Call centre services have an indirect nexus with the manufacturing activity as they help in building the brand image of the appellant, which ultimately leads to the sale of the final products. The services in relation to 'Sales Promotion' have a nexus with the manufacturing activity as sale is the most logical conclusion of the manufacturing activity and any effort made to boost the sale is bound to influence the manufacturing. Therefore, the credit on the call centre services is admissible to the appellant – Further, in respect of input services there is no requirement for admissibility of credit that services should received within the registered manufacturer/premises of the appellant till the time loose nexus can be established between the use of the services directly or indirectly in relation to output goods being manufactured by the appellant. The credit in such cases need not be denied - The services of ASC and DSC availed by the appellant definitely go to enrich the value of the output goods cleared by them by creating a brand image for the appellant. Hence, in terms of the Rule 2(l) of Cenvat Credit Rules, exists nexus between the said services and the goods being cleared by the appellant - Cenvat credit in respect of services provided at authorized service stations to the customers by the appellant is allowed – The impugned order is set aside and the appeal is allowed

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