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TMI Blog2025 (4) TMI 769X X X X Extracts X X X X X X X X Extracts X X X X ..... customer relationship management (CRO). Appellant had filed a claim for rebate of Service Tax as per Notification No.12/2005-ST dated 19.04.2005 for the period from July 2007 to September 2007. However, respondent issued a Show cause Notice and thereafter as per the impugned Order-in-Original rejected the claim on the ground that it is barred by limitation and also on the ground that the claim is unsustainable since it is consolidated claim and not for two registered premises separately. The adjudication authority also held that it is not possible to identify the input services with export services and correlation of FIRCs. Aggrieved by the said order, an appeal was filed before the Commissioner (Appeals) and as per the impugned Order, Com ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... vices are concerned. It was submitted that original application for registration was made for both the premises and filed with the department on 25.04.2005 and the single registration was issued by the Revenue only. Appellant had also filed consolidated ST-3 returns for both the premises. Moreover, the rebate claim applied for 2006-07 for both the premises was also granted in part." Same view was upheld by this Tribunal in Final Order No.20444/2019 dated 15.05.2019 in ST.No.331/2009-DB for the previous period in appellant's own case. 4. As regarding the nexus between the input and output services, learned counsel submits that the issue is squarely covered against each services as per the following chart : - Sl. No. Nature of Input Servi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ient for the purpose of granting rebate. Hence, certain omissions in terms of Rule 4A of the Service Tax Rules, 1994, cannot come in the way of sanctioning of rebate in respect of input services if the Appellant is able to show that there is an output service which has been exported. Ld counsel placed reliance in this regard in the matter of Aditya Birla Minacs Worldwide Ltd. v. Commissioner of Service Tax Bangalore -Service Tax, 2015-VIL-3382-CESTAT-BLR-ST (Para 6) & Aditya Birla Minacs Worldwide Limited v. Commissioner of Service Tax, Bangalore Service Tax-I, 2019-VIL-364-CESTAT-BLR-ST. 6. As regarding the interest, the learned counsel submits that in terms of Section 11BB of the Excise Act read with Section 83 of the Finance Act, the De ..... X X X X Extracts X X X X X X X X Extracts X X X X
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