CUSTOMS, EXCISE AND SERVICE TAX APPELLATE TRIBUNAL CHENNAI REGIONAL BENCH – COURT No. III Excise Appeal Nos. 40450 to 40454 of 2018 Excise Appeal Nos. 40456 to 40459 of 2018 (Arising out of Order-in-Appeal No. 405/2017(CTA-I) dated 24.11.2017 passed by Commissioner of GST and Central Excise (Appeals-I), No. 26/1, Mahatma Gandhi Road, Nungambakkam, Chennai – 600 034)

M/s. Godrej and Boyce Mfg. Co. Ltd. ...Appellant No. 1, SIDCO Industrial Estate, Chennai – 600 098.

Versus Commissioner of GST and Central Excise ...Respondent Chennai North Commissionerate, No. 26/1, Mahatma Gandhi Road, Nungambakkam, Chennai – 600 034.

APPEARANCE:

For the Appellant : Mr. M.N. Bharathi, Advocate For the Respondent : Mr. M. Selvakumar, Authorized Representative CORAM:

HON’BLE MR. P. DINESHA, MEMBER (JUDICIAL)

HON’BLE MR. VASA SESHAGIRI RAO, MEMBER (TECHNICAL)

FINAL ORDER Nos. 40264-40272 / 2026 DATE OF HEARING : 09.10.2025 DATE OF DECISION : 19.02.2026 Per Mr. VASA SESHAGIRI RAO The Appellant, M/s. Godrej & Boyce Mfg. Co.

Ltd., Ambattur, Chennai, is engaged in the manufacture of steel furniture and is duly registered with the Central Excise Department. During the period from April 2011 to October 2015, the Appellant availed CENVAT credit of service tax paid on various input services. On scrutiny of their records, the Department was of the view that certain credits were inadmissible on the ground that the impugned services were either outside the scope of “input service” under Rule 2(l) of the CENVAT Credit Rules, 2004, as amended w.e.f. 01.04.2011, or were hit by the exclusion clause, or were common services attributable to both dutiable manufacturing and exempt trading activities.

1.2 Accordingly, multiple Show Cause Notices/Statements of Demand were issued for different periods proposing recovery of irregular credit aggregating to ₹1,94,73,090/-, along with interest under Rule 14 read with Section 11AA/11AB of the Central Excise Act, 1944, and penalty under Rule 15 of the said Rules. The disputed credits related, inter alia, to commissioning and installation services, air travel/air ticketing, rent-a-cab and tour expenses, purchases sub-contract, loading/unloading, manpower hiring, and other allied services.

1.3 The Adjudicating Authority, vide Orders-in- Original Nos. 76 to 84/2016 dated 30.11.2016, allowed credit to the extent of ₹23,24,753/-, disallowed credit of ₹1,71,48,338/-, confirmed interest, and imposed penalty of ₹17,14,834/- under Rule 15(1). The Commissioner (Appeals), vide Order-in-Appeal No. 405/2017 dated

24.11.2017, upheld the adjudication orders, and hence the present eight appeals have been filed before this Tribunal.

2. The Ld. Advocate Mr. M.N. Bharathi, appeared for the Appellant and the Ld. Authorized Representative Mr.

M. Selvakumar, appeared for the Revenue.

3. The Learned Counsel Mr. M.N. Bharathi appearing for the appellant submitted as follows: -

i. the definition of “input service” under Rule 2(l), even after amendment w.e.f. 01.04.2011, continues to be of wide amplitude, covering services used directly or indirectly in or in relation to the Manufacture as well as services having a direct nexus with business operations of a manufacturer.

ii. It is the Appellant’s principal contention that the issue involved is no longer res integra, inasmuch as this Tribunal, in the Appellant’s own cases, for overlapping and subsequent periods governed by the same amended Rule 2(l), has allowed CENVAT credit on identical services. Strong reliance was placed on: -

a. Godrej & Boyce Mfg. Co. Ltd. v. Commissioner of Central Excise, Chennai-II, 2017 (48) STR 88 (Tri.-

Chennai);

b. Godrej & Boyce Mfg. Co. Ltd. v. Commissioner of GST

& Central Excise, Final Order Nos. 41636-

41638/2021; and

c. Godrej & Boyce Mfg. Co. Ltd. v. Commissioner of GST

& Central Excise, 2022-TIOL-136-CESTAT-MAD.

iii. It was submitted that these decisions were rendered after the amendment to Rule 2(l) and pertain to periods comparable to or later than the present dispute, and therefore c