𝗦𝗘𝗦𝗧𝗔𝗧 𝗠𝘂𝗺𝗯𝗮𝗶 𝗥𝘂𝗹𝗶𝗻𝗴 𝗼𝗻 𝗖𝗲𝗻𝘃𝗮𝘁 𝗖𝗿𝗲𝗱𝗶𝘁 𝗳𝗼𝗿 𝗠𝗶𝗻𝗶𝗻𝗴 𝗦𝗲𝗿𝘃𝗶𝗰𝗲𝘀 📢 𝗧𝗵𝗲 𝗧𝗿𝗶𝗯𝘂𝗻𝗮𝗹 𝗵𝗲𝗹𝗱: Registration is irrelevant without evidence of non-utilization of capital goods or eligibility for credit, even with different invoice addresses.

🔍 𝗙𝗮𝗰𝘁𝘀: 𝗖𝗼𝗺𝗽𝗮𝗻𝘆: M/s Seven Hills Constructions 𝗜𝘀𝘀𝘂𝗲: The appellant’s liability for recoveries under Rule 14 of CENVAT Credit Rules is under dispute due to ineligible credit and tax non-payment. 𝗔𝗰𝘁𝗶𝘃𝗶𝘁𝘆: The appellant, providing mining services, faced recovery of ₹1.28 crore for ineligible credit and unpaid tax on ₹6.96 crore earnings.

⚖️ 𝗝𝘂𝗱𝗴𝗲𝗺𝗲𝗻𝘁: The Tribunal remanded the case, highlighting that the adjudicating authority overlooked the Point of Taxation Rules, 2011, which changed taxation from receipts to accruals. It also failed to consider evidence of liability discharge on capital goods, instructing fresh disposal and granting the appellant a chance to present submissions.

📜 𝗖𝗮𝘀𝗲 𝗜𝗻𝗳𝗼𝗿𝗺𝗮𝘁𝗶𝗼𝗻: 𝗧𝗶𝘁𝗹𝗲: M/s Seven Hills Constructions vs. Commissioner of Service Tax, Mumbai – CENVAT Credit 𝗢𝗿𝗱𝗲𝗿 𝗗𝗮𝘁𝗲: 29 November 2022 📜 This ruling highlights the importance of proper documentation and legal consideration of the changed taxation regime in matters of CENVAT credit eligibility.