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2026 Supreme(Online)(CESTAT) 590

CUSTOMS EXCISE & SERVICE TAX APPELLATE TRIBUNAL
Somesh Arora, Member (Judicial)
Provana India Pvt Ltd – Appellant
Versus
Commissioner of CGST-Delhi East – Respondent


Advocates:
For the Appellants/Petitioners: Ms. Ankita Goel, Ms. Vaishali Jain, C.A.
For the Respondents: Shri Rohit Issar, Authorised Representative

SOMESH ARORA:

Briefly the facts of the present case are as follows:-

These two appeals have been filed by M/s Provana India Pvt. Ltd., as the appellants) against the orders of appellate authority as detailed in table below, The Adjudicating Authority vide its orders had partially sanctioned the refund claim filed by the appellants.

The order was upheld in appeal by Commissioner (Appeals)

2. Briefly stated, the appellants were registered with Service Tax under the category of Business Support Services. The appellants had filed claims for refund of unutilized CENVAT credit availed on input services used for exporting the Business Support Services and Information Technology Software Services. The claims were filed under Rule 5 of the CENVAT Credit Rules, 2004 read with Notification 27/2012-CE (NT) dated 18.06.2012. They had submitted the relevant documents viz copy of export/Commercial invoices. Reconciliation statement with respect to FIRO and expert invoices, copy of bank statements/ ledger, unjust enrichment certificate by CA, copy of input invoices, copy of Cenvat credit Register etc. along with the refund application.

2.1 The Appellants had filed the online refund claim on quarterly b

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