𝗖𝗘𝗦𝗧𝗔𝗧 𝗖𝗵𝗲𝗻𝗻𝗮𝗶 𝗥𝘂𝗹𝗶𝗻𝗴 𝗼𝗻 𝗥𝗲𝗴𝗶𝘀𝘁𝗿𝗮𝘁𝗶𝗼𝗻 𝗮𝗻𝗱 𝗖𝗘𝗡𝗩𝗔𝗧 𝗖𝗿𝗲𝗱𝗶𝘁 𝗥𝗲𝗳𝘂𝗻𝗱𝘀 📢 𝗧𝗵𝗲 𝗧𝗿𝗶𝗯𝘂𝗻𝗮𝗹 𝗿𝘂𝗹𝗲𝗱: "As there was no mandatory provision in the rules regarding registration, refund of CENVAT Credit cannot be denied for input invoices dated before registration."

🔍 𝗙𝗮𝗰𝘁𝘀: 𝗖𝗼𝗺𝗽𝗮𝗻𝘆: M/s. Saipem India Projects Limited 𝗜𝘀𝘀𝘂𝗲: M/s. Saipem India Projects Limited, engaged in engineering services for oil and gas projects, filed CENVAT Credit refund claims for July 2009 to March 2010. Initially denied due to pre-registration invoices and disputed service eligibility, the refund was later sanctioned by the lower appellate authority, leading the Revenue to appeal.

⚖️ 𝗝𝘂𝗱𝗴𝗺𝗲𝗻𝘁: The Tribunal held that CENVAT Credit refund cannot be denied for services used in business activities, even if incurred before centralized registration, as the rules do not mandate registration as a prerequisite. This follows precedents establishing that 'input service' broadly includes all business-related services. Revenue’s appeal was rejected.

📜 𝗖𝗮𝘀𝗲 𝗜𝗻𝗳𝗼𝗿𝗺𝗮𝘁𝗶𝗼𝗻: 𝗧𝗶𝘁𝗹𝗲: The Commissioner of Service Tax Vs M/s. Saipem India Projects Limited 𝗦𝗲𝗿𝘃𝗶𝗰𝗲 𝗧𝗮𝘅 𝗔𝗽𝗽𝗲𝗮𝗹 𝗡𝗼. 41499 of 2013 𝗢𝗿𝗱𝗲𝗿 𝗗𝗮𝘁𝗲: 12 June 2023 📜 This ruling reaffirms that input services used in business, even if incurred before registration, are eligible for CENVAT Credit refunds.