Indirect Services also qualify as Input Services

This ruling reinforces the expansive interpretation of “input service” by recognizing that modern manufacturing is not confined to factory-floor activities. 

The Tribunal acknowledged that risk management, financial hedging, employee training, and business travel are integral to efficient manufacturing operations.

The decision is particularly significant in rejecting a narrow, usage-based test and instead adopting a functional nexus test, where even indirect but essential services qualify for credit. It also reiterates that evidentiary burden must be assessed pragmatically and cannot be used to deny credit where business linkage is evident.