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TMI Blog2018 (2) TMI 808X X X X Extracts X X X X X X X X Extracts X X X X ..... t services based on the invoices issued by their corporate office. The department was of the view that the credit on various services is not eligible as the services were rendered at various other places for which the corporate office had made payments. SCN was issued proposing to deny the credit and to demand the same along with interest and also to impose penalties. After due process of law, the original authority confirmed the demand, interest and imposed penalties. Aggrieved, appellants are before the Tribunal. 2.1 On behalf of the appellants, the Ld. Counsel Shri S. Muthu Venkataraman assisted by Ms. Minchu Punnoose, submitted that the appellants have availed the credit based on the invoices issued by distribution of service tax credi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... re consumed in various branch offices as well as in administrative office. The service tax credit has been distributed by issuing ISD challans to various units. The services distributed through such ISD invoices do not have any nexus with the manufacturing activities of the appellants. Therefore, the credit has been rightly disallowed by the lower authority. 4. Heard both sides. 5.1 The period of dispute, the details of SCN and the amount involved as tabulated by the appellants shown as under:- Sl.No. SCN No. & Date Period of Dispute Amt. involved (Rs.) 1 No. 10/2010 dt.02.02.10 August 2005 to March 2009 1,60,86,994 2 No. V/15/73/36/2010 dt. 04.03.2010 April 2009 4,99,919 3 No. V/15/73/36/2010 dt. 10.03.2010 April 2009 4,9 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rvices whether qualify to be input services have been discussed in the decision of Ultratech Cement Ltd. and Coca Cola India Pvt. Ltd. (supra). The Hon'ble High Court in the above cases has observed that all the activities relating to the business of the assessees would qualify as input services. The services narrated above would sufficiently qualify as activities relating to the business of the manufacturer. Thus, following the dictum made by the Hon'ble High Court in the above judgments, we are of the view that the denial of credit is unjustified.
6. The impugned order is set aside and the appeal is allowed with consequential relief.
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