This content is restricted to site members. If you are an existing user, please log in. New users may register below.Existing Users Log InUsername or EmailPassword Remember Me Forgot password? Click here to resetNew User? Click here to register Post navigation HELD one transaction of sale of software and once it is accepted that the software put in the CD is ‘goods’, then there cannot be any separate service element in the transaction. We are saying so because even otherwise the user is put in possession and full control of the software. It amounts to ‘deemed sale’ which would not attract service tax. Central Excise Rules, 1944 HELD Tribunal have rightly denied the Modvat credit to the appellant on ‘Guide Car’ and rightly confirmed the demand of Rs. 45,86,664/- being the Modvat credit availed by the appellant on ‘Guide Car’.