2. The appellants TVS Motor Co. Ltd. (TVS) are claiming service tax paid in respect of the services rendered by TVS Finance and Services Ltd. (TVSFS) for financing sale of two-wheelers to ultimate customers in the premises of dealers of TVS. The credit amounting to Rs. 4,39,03,272/- has been denied by the adjudicating Commissioner leading to this appeal.

3. We find that the main reasons for rejecting the claim for credit are :-

(i) The service provided by TVSFS has no nexus to the manufacture of the two-wheelers by TVS.

(ii) The service provided is after the first sale of the two wheelers by TVS to its dealers and only rendered at the point of second sale to the ultimate customers at the dealers premises.

4. We find that the arguments advanced on behalf of the appellants that the service rendered by TVSFS helps the appellants to increase their sales and therefore the credit is admissible is prima facie not acceptable as the service rendered after the first sale is concluded and at the point of second sale of the manufactured excisable goods cannot be considered to be integrally connected to the manufacture of the goods. Both the arguments taken by the Department, prima facie, appear to be valid. We also find that in the case of CCE v. Manikgarh Cement [2010] 29 STT 230 (Bom.) the Hon'ble Bombay High Court has applied the tests laid down by the Hon'ble Supreme Court in the case of Maruti Suzuki Ltd. v. CCE 2009 (240) E.L.T. 641/ 22 STT 54 for denying credit of input service tax as the input service had no nexus. The tests laid down by the Hon'ble Supreme Court in the case of Maruti Suzuki Ltd. (supra) require that there must be nexus and the input must be integrally connected to the process of manufacture. The services rendered at the point of second sale cannot obviously be said to be integrally connected to the process of manufacture nor the manufacturing processes can be said to be dependent on receiving such input service. The manufacturing is already complete and the first sale is also complete before the impugned service is rendered at the premises of the dealer at the point of second sale. Hence, we are of the prima facie view that the appellants have not made out a case for complete waiver of the pre-deposit. Accordingly, we direct them to pre-deposit 50% of the amount of tax demanded within eight weeks from the date of pronouncement of this order and report compliance four weeks thereafter.