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IN THE CUSTOMS, EXCISE AND SERVICE TAX APPELLATE TRIBUNAL
WEST ZONAL BENCH, MUMBAI

Appeal No.E/361/2009-Mum

Arising out of Order-in-Appeal No.SN/01/NGP/2009 Dated 6/14.1.2009
Passed by the Commissioner of Central Excise(Appeals), Nagpur

Date of Decision: 7.7.2010

COMMISSIONER OF CENTRAL EXCISE, NAGPUR

Vs

M/s ULTRA TECH CEMENT LTD

Appellant Rep by: Shri S M Vaidya, JDR
Respondent Rep by: Shri Bharat Raichandani, Adv.

CORAM: Ashok Jindal, Member (J)

No where it is mentioned in rule 2(1) of the CENVAT Credit Rules, 2004 that the input service credit is not available for the services utilized outside the factory premises – Credit on account of services used for construction, erection, installation and other services like maintenance and repairs of the Fly Ash Plant situated outside the factory premises is admissible - Revenue appeal rejected: CESTAT

Cases relied upon –

Vikram Cements vs. Commissioner of Central Excise, Indore - (2006-TIOL-150-SC-CX)

ORDER NO.A/321/10/SMB/C-IV

Per: Ashok Jindal:

By this appeal, the Revenue is challenging the impugned order wherein the input service credit was allowed by the Commissioner(Appeals) to the respondent.

2. The facts of the case are that the respondents are manufacturer of cement. They are availing CENVAT credit of Service Tax under the provisions of Cenvat Credit Rules, 2004. The respondent availed CENVAT credit of Service Tax on account of services like for construction, erection, installation and other services like maintenance and repairs used in the Fly Ash plant situated at Thermal Power Plant which is outside of the factory premises. A show-cause notice was issued and demand was confirmed. Against that order, the respondent filed an appeal before the Commissioner(Appeals) who in turn allowed the appeal by relying on Vikram Cements vs. Commissioner of Central Excise, Indore 2006(197)ELT 145(SC) = (2006-TIOL-150-SC-CX) wherein the Hon’ble Apex Court has held that “the MODVAT/CENVAT credit on capital goods, if the mines are captive mines so that they constitute one integrated unit together with the concerned cement factory, MODVAT/CENVAT credit on capital goods will be available to the assessee”.

3. The learned DR submitted that in this case the respondent has availed the services at Thermal Power Plant which is outside the factory premises and the Commissioner(Appeals) has wrongly relied on the Vikram Ispat case as the facts are not similar. He further submitted that the Commissioner(Appeals) has not discussed the issue on merit whether the respondent is entitled to the CENVAT credit as per the Rule 2(l) of the CENVAT Credit Rules or not. Hence, the impugned order is liable to be set aside.

4. Heard and considered.

5. The CENVAT credit to the respondent was denied as proposed in the show-cause notice on the basis of that these services were received outside the factory premises. The CENVAT credit on input service is available as per Rule 2(1) of the CENVAT Credit Rules, 2004 which is reproduced here as under:-

i) used by a provider of taxable service for providing an output service, or

ii) used by the manufacturer, whether directly or indirectly, in or in relation to the manufacture of final products and clearance of final products from the place of removal,

and includes services used in relation to setting up, modernization, renovation or repairs of a factory, premises of provider of output service or an office relating to such factory or premises, advertisement or sales promotion, market research, storage up to the place of removal, procurement of inputs, activities relating to business, such as accounting, auditing, financing, recruitment and quality control, coaching and training, computer networking, credit rating, share registry, and security, inward transportation of inputs or capital goods and outward transportation up to the place of removal;

6. From the plain reading of the Rule 2(1) of the CENVAT Credit Rules, 2004, it is seen that no where it is mentioned that the input service credit is not available for the services utilized outside the factory premises. The denial of CENVAT credit on the ground that the services were not received by the respondent in the factory premises, is not sustainable. Accordingly, I do not find any merit in the appeal and the same is rejected.

(Pronounced in Court)

2010-TIOL-1165-CESTAT-MAD

IN THE CUSTOMS, EXCISE AND SERVICE TAX APPELLATE TRIBUNAL
SOUTH ZONAL BENCH, CHENNAI

Appeal No.ST/81/2009

Arising out of Order-in-Appeal No.35/2008 Dated : 30.10.2008
Passed by the Commissioner of Customs & Central Excise (Appeals), Tiruchirapalli

Date of Decision : 9.4.2010

M/s THE LAKSHMI VILAS BANK LTD

Vs

COMMISSIONER OF CENTRAL EXCISE, TRICHY

Appellant Rep by: Shri S Anandhan, Cons.
Respondent Rep by: Shri C Rangaraju, SDR

CORAM: Jyoti Balasundaram, VP

Service Tax – CENVAT Credit of service tax paid for construction of “Executive Staff Quarters” for the Bank – Credit is admissible as the input service includes “services used in the premises of a provider of output service”.

Appeal allowed.

FINAL ORDER NO.424/10

Per: Jyoti Balasundaram:

CENVAT credit of service tax paid for construction of “Executive Staff Quarters” at Karur has been disallowed to the assessees on the ground that the staff residential quarters cannot be construed as office relating to bank premises and, therefore, is not an “input service” in terms of Rule 2(1) of the CENVAT Credit Rules.

2. I have heard both sides. The definition of ‘input service’ includes “services used in the premises of a provider of output service”. There is no dispute that the staff quarters are the premises of the bank. Therefore, they are covered by the definition of ‘input service’ in Rule 2(1) and, therefore, they are entitled to take CENVAT credit of the entire service tax paid. I, therefore, set aside the impugned order and allow the appeal.

(Dictated and pronounced in open court)

An incident narrated by one of the Chartered Accounts who is the owner of a
big yahoo group on Indian taxation.
Dear All, This happened in Mumbai…… .

I cannot stop myself from sharing this with all of you. It all started when
I received a call from someone claiming that he was from my mobile service
provider and he asked me to shutdown my phone for 2 hours for 3G update to
take place. As I was rushing for a meeting, I did not question and shutdown
my cell phone.

After 45 minutes I felt very suspicious since the caller did not even
introduce his name. I quickly turned on my cell phone and I saw several
missed calls from my family members and the others were from the number that
had called me earlier - 3954380.

I called my parents and I was shocked that they sounded very worried asking
me whether I am safe. My parents told me that they had received a call from
someone claiming that they had me with them and asking for money to let me
free. The call was so real and my parents even heard ‘my voice’ crying out
loud asking for help. My parent was at the bank waiting for next call to
proceed for money transfer. I told my parents that I am safe and asked them
to lodge a police report.

Right after that I received another call from the guy asking me to shutdown
my cell phone for another 1 hour which I refused to do and hung up. They
keep calling my cell phone until the battery had run down. I myself lodged a
police report and I was informed by the officer that there were many such
scams reported. MOST of the cases reported that the victim had already
transferred the money! And it is impossible to get back the money.

Be careful as this kind of scam might happen to any of us!!! Those guys are
so professional and very convincing during calls. If you are asked to shut
down your cell phone for updates by the service provider, ASK AROUND! Your
family or friends might receive the same call.

Be Safe and Stay Alert!

Palm Sunday

Jesus entering Jerusalem on a donkey.
Palm Sunday is a Christian moveable feast which always falls on the Sunday before Easter Sunday. The feast commemorates an event mentioned by all four Canonical Gospels Mark 11:1-11, Matthew 21:1-11, Luke 19:28-44, and John 12:12-19: the triumphant entry of Jesus into Jerusalem in the days before his Passion. It is also called Passion Sunday or Palm Sunday of the Lord’s Passion.
In many Christian churches, Palm Sunday is marked by the distribution of palm leaves (often tied into crosses) to the assembled worshipers. The difficulty of procuring palms for that day’s ceremonies in unfavorable climates for palms led to the substitution of boughs of box, yew, willow or other native trees. The Sunday was often designated by the names of these trees, as Yew Sunday or by the general term Branch Sunday.
According to the Gospels, before entering Jerusalem, Jesus was staying at Bethany and Bethphage, and the Gospel of John adds that he had dinner with Lazarus, and his sisters Mary and Martha. While there, Jesus sent two disciples to the village over against them, in order to retrieve a donkey that had been tied up but never been ridden, and to say, if questioned, that the donkey was needed by the Lord but would be returned. Jesus then rode the donkey into Jerusalem, with the Synoptics adding that the disciples had first put their cloaks on it, so as to make it more comfortable. The Gospels go on to recount how Jesus rode into Jerusalem, and how the people there lay down their cloaks in front of him, and also lay down small branches of trees. The people sang part of Psalm 118 - …Blessed is He who comes in the name of the Lord. Blessed is the coming kingdom of our father, David. … (Psalms 118:25-26). Where this entry is supposed to have taken place is unspecified; some scholars argue that the Golden Gate is the likely location, since that was where it was believed the Jewish messiah would enter Jerusalem; other scholars think that an entrance to the south, which had stairs leading directly to the Temple, would be more likely.
Symbolism
It is a common custom in many lands in the ancient Near East to cover, in some way, the path of someone thought worthy of the highest honour. The Hebrew Bible (2Kings 9:13) reports that Jehu, son of Jehoshaphat, was treated this way. Both the Synoptic Gospels and the Gospel of John report that people gave Jesus this form of honour. However, in the synoptics they are only reported as laying their garments and cut rushes on the street, whereas John more specifically mentions palm fronds. The palm branch was a symbol of triumph and of victory, in Jewish tradition, and is treated in other parts of the Bible as such (e.g. Leviticus 23:40 and Revelation 7:9). Because of this, the scene of the crowd greeting Jesus by waving palms and carpeting his path with them has given the Christian festival its name.
Christians often interpret a passage from Zechariah as a prophecy which was fulfilled by the Triumphal Entry:

Rejoice greatly, O Daughter of Zion!
Shout, Daughter of Jerusalem!
See, your king comes to you,
righteous and having salvation,
gentle and riding on a donkey, on a colt, the foal of a donkey.
I will take away the chariots from Ephraim
and the war-horses from Jerusalem,
and the battle bow will be broken.
He will proclaim peace to the nations.
His rule will extend from sea to sea
and from the River to the ends of the earth.
—Zechariah 9:9-10
Matthew quotes this passage from Zechariah when narrating the story of Jesus’ entry to Jerusalem. His interpreting of the repetition in the Hebrew poetry as describing two different donkeys: gentle and riding on a donkey, on a colt, the foal of a donkey, is offered by some Biblical scholars as a reason for Matthew’s unique description of Jesus riding both a donkey and its foal. However, there is an alternate explanation. The full text in Matthew regarding this issue is as follows:
“And when they drew nigh unto Jerusalem, and were come to Bethphage, unto the mount of Olives, then sent Jesus two disciples, 2 Saying unto them, Go into the village over against you, and straightway ye shall find an ass tied, and a colt with her: loose them, and bring them unto me. 3 And if any man say ought unto you, ye shall say, The Lord hath need of them; and straightway he will send them. 4 All this was done, that it might be fulfilled which was spoken by the prophet, saying, 5 Tell ye the daughter of Sion, Behold, thy King cometh unto thee, meek, and sitting upon an ass, and a colt the foal of an ass. 6 And the disciples went, and did as Jesus commanded them, 7 And brought the ass, and the colt, and put on them their clothes, and they set him thereon.” (Matthew 21:1-7 KJV)
The Septuagint, in Zechariah9:9 says: “Rejoice greatly, O daughter of Sion; proclaim it aloud, O daughter of Jerusalem; behold, the King is coming to thee, just, and a Saviour; he is meek and riding on an ass, and a young foal.” (Brenton) The wording is slightly different from the Hebrew text but one can reasonably interpret from the text that the Messiah, Jesus, will be riding on one of the animals, presumably the ass, or donkey, and that its colt, or foal, will be following behind its mother. To imagine that Jesus would be riding on both simultaneously would indeed present a strange image to mind. Hilary of Poitiers, in one of his sermons on this chapter of Matthew, is of the view that two animals, the ass and its colt, were brought to Jesus and, presumably, those animals were not separated when he rode into Jerusalem: “Two disciples are sent to the village to loosen the ass tied up with its colt and to bring them to him. And should someone ask them why they are doing that, they are to respond that the Lord needs the animals, which must be released to him without delay. From the previous sermons we remember that the two sons of Zebedee symbolize the double vocation of Israel. Therefore, now it is fitting to interpret the two disciples sent to release the ass and the colt as the subsequent double vocation of the Gentiles. It applies first of all to the Samaritans, who abandoned the law after their dissent and lived in a state of dependence and servitude. Yet it also applies to the rebellious and ferocious Gentiles. Therefore the two disciples are sent to loosen those who were bound and arrested by the bonds of error and ignorance.”
A widespread Jewish belief states that the Mount of Olives would see the coming of the Messiah This belief is based upon Zechariah 14:3-4:
Then shall the Lord go forth and fight against those nations, as when he fought in the day of battle. And his feet shall stand in that day upon the Mount of Olives, which is before Jerusalem on the east .
Dates for Palm Sunday, 2009-2020
Year Western Eastern
2009 April 5 April 12
2010 March 28
2011 April 17
2012 April 1 April 8
2013 March 24 April 28
2014 April 13
2015 March 29 April 5
2016 March 20 April 24
2017 April 9
2018 March 25 April 1
2019 April 14 April 21
2020 April 5 April 12

On the ensuing “International Financial Reporting System” I am going give a synopsis of the Accounting Standards do undergo changes. Topi by Topic, I am going to deliberate which may be of help. Keep a close watch of this site ‘LOUISRAJ.COM’

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