Mutual fund redemption not "trading of goods"; no CENVAT reversal or extended limitation under Service Tax
Last updated: 24 February 2026
Court :
CESTAT New Delhi
Brief :
The CESTAT New Delhi in the case of Godfrey Phillips India Limited v. Commissioner, Central Tax, GST, Delhi East [Final Order No. 51817/2025, order dated December 5, 2025] held that subscription and redemption of Mutual Fund units cannot be considered "trading of goods/securities" under Section 66D(e) of the Finance Act, 1994 as it lacks transfer of title, involves unit cancellation/relinquishment rather than sale/purchase to third party, and thus does not qualify as "exempted service" requiring proportionate CENVAT credit reversal under Rule 6(3) of CENVAT Credit Rules, 2004.
Citation :
Final Order No. 51817/2025, order dated December 5, 2025
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Bimal Jain
Published in Community & General
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