Chartered Accountant
Bookmark and Share
click here to subscribe our newsletter
 
 
Corporate News *   CBIC issues draft rules for Customs valuation *  Top Headlines: Threshold for Benami deals, green bond investors, and more *  Govt aims 1-hour clearance for goods at all ports *  Exporters Allowed To Use RoDTEP, RoSCTL Scrips To Pay Customs Duty, Transfer Them; Rules Amended *  Millions of labourers to be affected by brick producers’ strike over hike in GST, coal rates *  Inauguration of ‘kendriya GST parisar’ *  Transporter can seek Release of Conveyance alone, not Goods under GST Act: Madras HC *  GST: Quoting of DIN Mandatory for Responding to Notice, Govt Modifies Portal *  Firms can soon file claims for GST credits of ?400 cr *  CBIC issues modalities for filing transitional credit under GST. *  Mumbai: Man creates 36 fake GST firms, arrested for input tax credit fraud of Rs 23 cr *  Report to restructure Commerce Ministry under study; idea is to set up trade promotion body: Goyal *  Firms can soon file claims for GST credits of ?400 cr *  Gambling Alert! Govt May Levy Up To 28% GST; UP, Bengal Back Move *  EPFO backs raising retirement age to ease pressure on pension funds *  India Moving Up Power Scale, Set to Become Third Largest Economy By 2030 *  Airfares Get Expensive: What Changes for Flyers From Today? *  IRCTC Latest News: Passengers to Pay More For Cancelling Confirmed Rail Tickets Soon. *  IBC prevails over Customs Act, says Supreme Court. *  As GST enters sixth year, a time for evaluation and reassessment *  There’s GST on daily essentials as Centre needs money to buy MLAs: Arvind Kejriwal *  Now, GST on cancellation of confirmed train tickets, hotel bookings *  GST kitty for top States could rise 20% in FY23, says Crisil *  French customs officials seize another cargo vessel over Russia sanctions *  TradeLens builds on Asia momentum with Pakistan Customs deal *  Hike tax on tobacco, reduce affordability & increase revenue: Civil society organizations to GST council *  Bihar: ?10 crore tax evasion on tobacco products detected in raids *  Centre failed on GST, COVID; would it be anti-national? Rajan on Infosys row *  Service Tax not Chargeable on Income Tax TDS portion paid by recipient: CESTAT grants relief to TVS *  Foreign portfolio investors make net investment of Rs 7575cr in Sep so far
Subject News *  Run-up to Budget: Monetary threshold for GST offences may rise to Rs 25 cr *   GST (Tax) E-invoice Must For Businesses With Over Rs 5 Crore Annual Turnover *   Both Central GST and excise duty can be imposed on tobacco, rules Karnataka high court *   CBIC Issues Clarification On Extended Timelines For GST Compliance *   CBIC Issues Clarification On Extended Timelines For GST Compliance *  Budget 2023- 9.6 crore gas connections *  GST: Tamil Nadu Issues Instructions for Assessment and Adjudication Proceedings *  GST: CBIC Extends Last Date for filing of ITC *  GST collection in September surpasses Rs 1.4 lakh crore for straight seventh time *  Dollar smuggling case: Customs chargesheet names M Sivasankar as key conspirator. *  Hike in GST rates fuels inflation *  Assam: CBI arrests GST commissioner in Guwahati *  GST fraud worth ?824cr by 15 insurance Cos detected *  India proposes 15% customs duties on 22 items imported from UK *  Decriminalising certain offences under GST on cards *  Surge in GST collections more due to higher inflation: India Ratings *  MNRE Notifies BCD and Hike in GST Rates as ‘Change in Law’ Events But With a Condition | Mercom India *   Solar projects awarded before customs duty change allowed cost pass-through *  Rajasthan High Court Dismisses Writ Petitions Challenging Levy Of GST On Royalty *   GST revenue in September likely at Rs 1.45 lakh crore *  Govt working on decriminalising certain offences under GST, lower compounding charge *  Building an institution like GST Council takes time, trashing is easy: Sitharaman *  GST collections in Sept may touch ?1.5 lakh crore *  KTR asks Centre to withdraw GST on handlooms *  After Gameskraft, More Online Gaming Startups To Receive GST Tax Claims *  Madras HC: AAR Application Filed Under VAT Does Not Survive After GST Enactment *  Threshold for criminal offences under GST law may be raised *  Bengaluru: Gaming company faces biggest GST notice of Rs 21,000 crore *  CBIC clarifies Classification of Cranes for GST, Customs Duty *  Customs seize gold hidden in bicycle in Kerala airport  

Comments

Print   |    |  Comment

PJ/CASE LAW/2015-16/2986

whether cenvat credit proportionate to the amount recovered from the employees/workers of the appellant is required to be disallowed to the appellant or not?

Case: CEMA ELECTRIC LIGHTING PRODUCTS INDIA P. LTD. versus C.C.E., AHMEDABAD-III

Citation:2015 (37) S.T.R. 754 (Tri. - Ahmd.)

Brief Fact:The issue involved in this case is whether in case of outdoor catering service, credit of service tax proportionate to the amount recovered from the employees/beneficiaries of canteen is admissible to the appellant or not. Under the above impugned order, Commissioner (Appeals) has rejected the reliance placed by the appellant on the judgment of the Larger Bench decision of the Tribunal in the case of Commissioner of Central Excise, Mumbai v. GTC Industries Limited [2008 (12)S.T.R. 468 (Tri.-LB.)] in the light of the decision of the Hon’ble High Court of Bombay in the case of Ultratech Cement Limited [2010 (260)E.L.T. 369 (Bom.) = 2010 (20)S.T.R. 577], hence the present appeal.

Appellant contention: Learned consultant of the appellant argued that as per the Factories Act, the State Government; by Rules make it mandatory for the units to run a canteen where more than 250 workers are ordinarily employed. It was further argued that as per the Rule 78(2)(g) of the Gujarat Factories Rules, 1963, only non-profit charges are to be recovered from the workers/employees for such food, drink or other items supplied but the amount recovered shall not take into consideration, the wages of the employees serving in the canteen and the cost of uniform if any provided. It was, therefore, argued that as per the relevant Factories Act and the Gujarat Factories Rules, 1963, no element of service tax has been recovered from the employees of the unit. It was further argued that this case is covered by the Larger Bench decision of the Tribunal in the case of Commissioner of Central Excise, Mumbai-V v. GTC Industries Limited (supra). It was also argued by the appellant that the demand is time-barred because the short levy was detected during the second audit of their unit and the details of credit taken were regularly shown in the returns. It was argued that for repeated audits, extended period cannot be invoked when it was not detected in the first audit by the Revenue authorities. Appellants relied upon the judgment of Hon’ble High Court of Karnataka in the case of Commissioner of Central Excise, Bangalore v. MTR Foods Limited [2012 (282)E.L.T. 196 (Kar.)] and Ahmedabad Bench decision in the case of Kay Kay Press Metal Corporation v. CCE, Valsad [2011 (270)E.L.T. 691 (Tri.-Ahmd.)].
 
Respondent contention:Learned AR on the other hand relied upon the decision of the Hon’ble High Court of Bombay in the case of Commissioner of Central Excise Nagpur v. Ultratech Cement Limited [2010 (20)S.T.R. 577 (Bom.)]. He would mainly emphasize on Para 39 of the judgment, which is discussed by Commissioner (Appeals) in Para-4 of the impugned order dated 14-3-2012, that cenvat credit with respect to proportionate credit to the extent embedded in the cost of food recovered from the employees/workers is required to be reversed. On the point of time-bar, he argued that the fact of recovery of amount from the employees/workers was not made known to the department, therefore the judgments relied upon by the appellant regarding time-bar are not applicable to the facts and circumstances of this case.
 
Reasoning of Judgment:In this appeal, there are two issues required to be decided. The first issue is whether cenvat credit proportionate to the amount recovered from the employees/workers of the appellant is required to be disallowed to the appellant or not. The second issue is whether limitation under Section 11A of the Central Excise Act will be applicable when the credit improperly taken has been noticed during the course of second audit.
So far as the first issue is concerned, the appellant has relied upon the Larger Bench decision of the Tribunal in the case of GTC Industries Limited (supra). It is noticed that Hon’ble High Court of Bombay in the case of Ultratech Cement Limited (supra) has held as follows :-
“39. The Larger Bench of CESTAT in the case of GTC Industries Ltd. (supra) has also observed that the credit of service tax would be allowable to a manufacturer even in cases where the cost of the food is borne by the worker (see last para). That part of the observation made by the Larger Bench cannot be upheld, because, once the service tax is borne by the ultimate consumer of the service, namely the worker, the manufacturer cannot take credit of that part of the service tax which is borne by the consumer. Shri Shridharan, learned Counsel for the assessee fairly conceded to the above position in law and in fact filed an affidavit affirmed by a responsible officer of the assessee wherein it is stated that the proportionate credit to the extent embedded in the cost of food recovered from the employee/worker has been reversed.”
From the above, it is seen that the Hon’ble High Court of Bombay has held that once proportionate service tax is borne by the ultimate consumer of the service, namely the worker/beneficiary, the manufacturer cannot take credit of that part of the service tax which is borne by the consumer. In view of this judgment, proportionate credit, to the extent it is embedded in the cost of food recovered from the employee/beneficiary, is not admissible to the appellant. In fact, it is clear from the facts narrated in Para-2 of the show cause notice dated 15-10-2010 issued to the appellant that demand is made only with respect to that amount which is recovered from the beneficiary/employees of the appellant. The argument of the appellant that no element of service tax is recovered from the beneficiary/employee stands defeated in view of the Hon’ble High Court of Bombay judgment in the case of Ultratech Cement Limited. It has been rightly held by Commissioner (Appeals) in his findings that no evidence has been produced by the appellant to the effect that service tax element embedded in the payment received from the employees is not recovered from the employees/beneficiary. Like a concept of unjust enrichment for refunds under Section 11B of the Central Excise Act, 1944, the onus is on the appellant to establish with documentary evidence that the element of service tax paid by the appellant is not recovered from the beneficiary/employees of the appellant. On merits, therefore, the case goes against the appellant and in favour of the Revenue.
The second issue is regarding application of limitation under Section 11A of the Central Excise Act, 1944, the appellant has relied upon the two judgments, as mentioned in Para 3 above. The first judgment in the case of MTR Foods Limited (supra), the issue involved was with respect to cenvat credit taken by M/s. MTR Foods Limited on pre-fabricated (construction) building (cold rooms) consisting of wall, roof, door, flashing window on an assumption that they are required to manufacture final products. In Para 4 of this judgment it was held by the Hon’ble High Court of Karnataka that the returns filed by the appellant in that case clearly mentioned that they have availed the cenvat credit with respect to pre-fabricated (construction) building etc. and the first audit party accepted the same and only during the second audit they noticed the mistake and initiated recovery proceedings. In this appeal, the order of the Tribunal was upheld by the Hon’ble High Court on limitation itself, without going into the merits of the case. In the present case, no documentary evidence has been brought forward by the appellant that they indicated the amounts recovered from the beneficiaries/employees in the monthly returns filed with the department. As no such details are forthcoming to have been brought to the notice of the department and the same could be known by the department only during the course of second audit. In the case of MTR Foods Limited, the inputs on which the cenvat credit was taken was pre-fabricated (construction) buildings etc. and the credit admissibility was exempted with respect to the inputs and there was no situation where a part of cenvat credit taken with respect to the amounts recovered from the employees/beneficiaries was the subject matter of denial of cenvat credit. The facts in this case are therefore, different inasmuch as no separate data were given by the appellant to the department in the monthly returns. The judgment of the Hon’ble High Court of Karnataka, in the case of MTR Foods Limited (supra) is therefore, distinguishable on facts.
In the case of Kay Kay Press Metal Corporation v. CCE, Valsad (supra), the issue involved was whether the activities undertaken by the appellant such as cutting, bending and punching of duty paid articles, plates or channels will amount to manufacture or not. It was held by the Tribunal that these activities do not amount to manufacture. As in that case, the nature of activities undertaken by the assessee were known to the department, it was held that extended period cannot be invoked in the facts and circumstances of that case. Whereas in the present appeal, the fact that certain amounts were recovered from the beneficiaries/workers by the appellants, was suppressed from the department and the same came to the knowledge of the department only through an audit and therefore, the judgment in the case of Kay Kay Press Metal Corporation (supra) is not applicable to the facts and circumstances of this case and is thus distinguishable.
On the basis of above observations, the order-in-appeal dated 14-3-2012 is required to upheld. Accordingly, the appeal filed by the appellant is rejected.

Decision:  Appeal rejected

Comment: The essence of the case is that proportionate service tax is borne by the ultimate consumer of the service, namely the worker/beneficiary; the manufacturer cannot take credit of that part of the service tax which is borne by the consumer.As well as no evidence has been produced by the appellant to the effect that service tax element embedded in the payment received from the employees is not recovered from the employees/beneficiary. Like a concept of unjust enrichment for refunds under Section 11B of the Central Excise Act, 1944, the onus is on the appellant to establish with documentary evidence that the element of service tax paid by the appellant is not recovered from the beneficiary/employees of the appellant. On merits, therefore, the case goes against the appellant and in favour of the Revenue.
 
Prepared By:Anash kachaliya
 

Department News


Query

 
PRADEEP JAIN, F.C.A.

Head Office : -

Address :
"SUGYAN", H - 29, SHASTRI NAGAR, JODHPUR (RAJ.) - 342003

Phone No. :
0291 - 2439496, 0291 - 3258496

Mobile No. :
09314722236

Fax No. :0291 - 2439496


Branch Office : -

Address:
1008, 10th FLOOR, SUKH SAGAR COMPLEX,
NEAR FORTUNE LANDMARK HOTEL, USMANPURA,
ASHRAM ROAD, AHMEDABAD-380013

Phone No. :
079-32999496, 27560043

Mobile No. :
093777659496, 09377649496

E-mail :pradeep@capradeepjain.com