TMI Blog2015 (7) TMI 633X X X X Extracts X X X X X X X X Extracts X X X X ..... ch, they have not incurred the entire advertisement expenses from their pocket. - Held that:- Merely because the appellants stand reimbursed part cost of the advertising expenses from their parent company, does not mean that the appellants would become disentitled to the Service Tax actually paid by them. As rightly pleaded before us, the financial arrangement between the subsidiary company and th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... y, they are entitled to the Cenvat credit of Service Tax so paid by them on the advertising cost. 2. As the appellant is a 100% subsidiary of their parent company located in Japan, the part of the advertising expenditure incurred by them are being received by them from their parent company. The Revenue s only objection for denial of Cenvat credit of Service Tax paid by the appellant is that the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... id by them. Revenue should not be concerned with further financial arrangements between parent company and the subsidiary company. 4. Countering the argument, learned DR reiterates the reasoning of the adjudicating authority and submits that in spite of making promises to produce an agreement between the subsidiary company and parent company before the adjudicating authority, the appellant have ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... llants stand reimbursed part cost of the advertising expenses from their parent company, does not mean that the appellants would become disentitled to the Service Tax actually paid by them. As rightly pleaded before us, the financial arrangement between the subsidiary company and the parent company has no connection or relevance for the purpose of availability of credit of Service Tax paid by the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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