PER : P.A. AUGUSTIAN

The issue in the present appeal is regarding refund of unutilized CENVAT credit of input service. Appellant is an 100% Software Oriented Unit and Export of Services as well as providing services of DTA. Appellant had filed nine (9) refund claims on unutilized CENVAT Credit for the period from June 2012 - September 2014 however against claim of Rs.74,92,20,484/- only an amount of Rs.35,88,48,080/- is allowed by the Adjudication Authority. Aggrieved by the said orders, appeals were filed before the Commissioner (Appeals) and Commissioner (Appeals) also allowed Rs.25,67,86,392/- and denied refund of Rs.13,35,86,012/-. Aggrieved by said orders present appeals are filed. Details of the appeals are given below:-

2. When the appeals came up hearing, Learned Chartered Accountant (CA) for the appellant submits that the considerable part of the claim made by the appellant which is rejected by the Adjudication Authority / Appellate Authority is regarding Business Support Service (BSS) and it is denied on the ground that there is no nexus between the input and output services. The total amount rejected on the Business Support Service (BSS) is Rs.5,92,82,435/-. As regarding V