𝗦𝗲𝗿𝘃𝗶𝗰𝗲 𝗧𝗮𝘅 – 𝗖𝗘𝗦𝗧𝗔𝗧 𝗞𝗼𝗹𝗸𝗮𝘁𝗮: 𝗡𝗼 𝗧𝗶𝗺𝗲 𝗟𝗶𝗺𝗶𝘁 𝗳𝗼𝗿 𝗖𝗲𝗻𝘃𝗮𝘁 𝗖𝗿𝗲𝗱𝗶𝘁 𝗧𝗮𝗸𝗲𝗻 𝗕𝗲𝗳𝗼𝗿𝗲 11.07.2014 📢 𝗧𝗵𝗲 𝗧𝗿𝗶𝗯𝘂𝗻𝗮𝗹 𝗵𝗲𝗹𝗱: The 2014 Cenvat credit time limit applies prospectively, not retrospectively, to invoices issued before the amendment date.

🔍 𝗙𝗮𝗰𝘁𝘀: 𝗖𝗼𝗺𝗽𝗮𝗻𝘆: ITC Sonar (Unit of ITC Limited) 𝗜𝘀𝘀𝘂𝗲: Cenvat credit was not rightly disallowed for invoices issued before 11.07.2014, and penalty under Rule 15 was unjustified. 𝗔𝗰𝘁𝗶𝘃𝗶𝘁𝘆: The appellant was issued a show cause notice for irregular Cenvat credit on invoices dated 2014-2015, beyond the six-month period.

⚖️ 𝗝𝘂𝗱𝗴𝗲𝗺𝗲𝗻𝘁: The Tribunal ruled that the six-month limitation introduced in Rule 4(1) of the Cenvat Credit Rules applies only to invoices issued after 01.09.2014. It clarified that the amendment is not retrospective, referencing the Voss Exotech case, and thus does not apply to invoices before 11.07.2014.

📜 𝗖𝗮𝘀𝗲 𝗜𝗻𝗳𝗼𝗿𝗺𝗮𝘁𝗶𝗼𝗻: 𝗧𝗶𝘁𝗹𝗲: ITC Sonar vs. Commissioner of Service Tax – Service Tax 𝗢𝗿𝗱𝗲𝗿 𝗗𝗮𝘁𝗲: 17 November 2022 📜 The ruling clarifies that the 2014 Cenvat credit time limit applies only to invoices issued after 11.07.2014.