TMI Blog2018 (6) TMI 628X X X X Extracts X X X X X X X X Extracts X X X X ..... acture and clearance of the goods, which were ultimately exported - Held that:- It is seen that the Revenue in the memo of appeal have challenged the findings of Commissioner (Appeals) on merits but there is no ground challenging his order on non-applicability of extended period. As such, though on merits also this order cannot be faulted upon but in the absence of any specific challenge to the fi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... HA services, Fumigation Services and Environ Care Services availed by the assessee at the port area during the period Sept.'04 to Dec.'08. The original adjudicating authority had denied the credit by observing that the services stand obtained beyond the place of removal, which is the factory gate and as such, have no nexus with the manufacture and clearance of the goods, which were ultimat ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... is seen that the Revenue in the memo of appeal have challenged the findings of Commissioner (Appeals) on merits but there is no ground challenging his order on non-applicability of extended period. As such, we note that though on merits also this order cannot be faulted upon but in the absence of any specific challenge to the findings on limitation, we are of the view that the impugned order would ..... X X X X Extracts X X X X X X X X Extracts X X X X
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