CUSTOMS, EXCISE AND SERVICE TAX APPELLATE TRIBUNAL CHANDIGARH REGIONAL BENCH - COURT NO. I Excise Appeal No. 52370 of 2015 [Arising out of Order-in-Original No. 07/MV/CCE/2014-15 dated 20.03.2015 passed by the Commissioner of Central Excise, Gurgaon]

N H K Spring India Ltd ……Appellant Plot No. 31, Sector 3, IMT Manesar, Gurugram, Haryana 122050 VERSUS Commissioner of Central Excise, Goods & ……Respondent Service Tax, Gurugram Plot No. 36-37, Sector 32, Gurugram, Haryana 122001 APPEARANCE:

Ms. Krati Singh and Ms. Samiksha Uniyal, Advocates for the Appellant Ms. Amita Gupta, Authorized Representative for the Respondent CORAM: HON’BLE Sh. S. S. GARG, MEMBER (JUDICIAL) HON’BLE Sh. P. ANJANI KUMAR, MEMBER (TECHNICAL)

FINAL ORDER NO. 60317/2026 DATE OF HEARING: 09.01.2026 DATE OF DECISION: 28.04.2026 S. S. GARG :

The present appeal is directed against the impugned Order-in-

Original dated 20.03.2015 passed by the Commissioner of Central Excise, Gurgaon, whereby the learned Commissioner has denied the Cenvat Credit availed by the Appellant on various input services for the period 2007-08 to 2011-12 and confirmed the demand of Rs.73,74,267/- under Rule 14 of the Cenvat Credit Rules, 2004 read with Section 11A(5) of the Central Excise Act, 1944 along with the interest under Section 11AA of the Act and also imposed penalty under Rule 15 of the CCR read with Section 11AC of the Act.

2. Briefly stated facts of the case are that the Appellant is engaged in the manufacturing of Motor Vehicle Parts falling under Central Excise Tariff Headings No. 73209090 & 87081090 of the First Schedule to the Central Excise Tariff Act, 1985. During the relevant period, the Appellant availed Cenvat Credit of excise duty paid on inputs and capital goods and service tax paid on input services.

2.1 Audit of the Appellant’s unit was conducted and during the audit, it was observed that the Cenvat Credit availed by the Appellant in respect of various input services namely House Keeping (Gardening), Vehicles Servicing, Tour & Travel, Outward Courier, Interior Decoration, Construction, Surface Colouring/Coating, Fabrication and Insurance Services is ineligible as the said services do not have nexus with the manufacturing process and the manufacturing can be completed without the use of these services also. On these allegations, a show cause notice dated 30.10.2012 was issued proposing denial of Cenvat Credit, along with interest and penalty.

2.2 After following the due process, the learned Commissioner vide the impugned order has confirmed the demand as proposed in the show cause notice, along with interest and penalty. Details of various input services on which the demand has been confirmed by the learned Commissioner are given herein below in tabular form:

2.3 Aggrieved by the impugned order passed by the learned Commissioner, the Appellant has preferred the present appeal before us.

3. Heard both the parties and perused the material on records.

4. The learned Counsel for the Appellant submits that the impugned order is bad in law and is liable to be set aside as the same has been passed without properly appreciating the facts and the law and binding judicial precedents on the identical issue.

4.1 She further submits that the Appellant has legally and correctly availed the Cenvat Credit on input services. She further submits that the demand has been confirmed on the ground that the Appellant has wrongly availed the Cenvat Credit of the service tax paid on certain input services on the ground that the said services do not qualify as input services under Rule 2(l) of the Cenvat Credit Rules. She further submits that the services received by the Appellant are in fact input services and the same fall within the means-clause of the input service as defined in Rule 2(l) of the Cenvat Credit Rules and the same have been used in relation to the manufacture of final products and clearance of the final products from/upto the place of removal. She further submits that the use of the p