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TMI Blog2018 (8) TMI 1569X X X X Extracts X X X X X X X X Extracts X X X X ..... ut services. During the course of verification of accounts for the period from April 2015, June 2015, July 2015, September 2015 and November 2015, it was noticed that the appellants had availed service tax credit for various services like Garden upkeep, Interior Decorator service, Renting of immovable property services and other services which were not eligible. 3. Show cause notice was issued proposing to deny the credit on these services. After due process of law, the original authority disallowed the credit in respect of certain services and confirmed the demand, interest and imposed penalties. In appeal, the Commissioner (Appeals) disallowed the credit in respect of garden upkeep services, interior decorator services, renting of immova ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... herefore being post manufactrure expenses have no nexus with manufacturing activity. He submitted that the sales offices are used for procuring orders and coordinating with customers for the purpose of supply of materials, its installation and doing market research. These activities are integral to the manufacturing activity and therefore is eligible for credit. He relied upon the decision in the case of Carrier Airconditioning & Refrigeration Ltd. Vs C.C.E., Delhi-IV 2016 (41) S.T.R. 824 (Tri. - Chan.) 5. The Ld.AR, Sh.R.Subramanian supported the findings in the impugned order. He submitted that al the above services do not have nexus with the manufacturing activity and therefore the authorities below have rightly denied the credit. In r ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ect of branch offices. It is consistently argued by the appellants that they have setup branch offices in various places from where they collected sales orders from customers and follow up for supply of materials, payments and after sales coordination. A similar issue was analysed by the Tribunal in the case of Carrier Air conditioning & Refrigeration Ltd. (supra). The Tribunal observed that the credit availed on the renting of branch offices was eligible. Following the same, I am of the view that the disallowance of credit is improper and requires to be set aside which I hereby do. 10. In the result, the impugned orders are modified to the extent of allowing credit in respect of garden services, interior decorator services and renting of ..... X X X X Extracts X X X X X X X X Extracts X X X X
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