Refund on GTA export services sustained despite document objections and circular-based verification concerns.

Refund of service tax paid on GTA services for export under Notification No. 41/2007-ST was held admissible despite objections about the transporter's registration number, document correlation, the refund worksheet, and random verification. Because the service tax was paid by the exporter under reverse charge, there was no need for the transporter's service tax registration number on the lorry receipts. Correlation between transport documents and shipping bills was established through purchase order and invoice numbers. The objections regarding the amount rejected, non-supply of the worksheet, and multiple locations were found meritless, and the Board circular's random verification requirement was treated as an administrative instruction, not a legal precondition to deny refund.

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Issues: Whether refund of service tax paid on GTA services for export under Notification No. 41/2007-ST was admissible despite the transport documents not showing the transporter's service tax registration number, alleged mismatch in correlation documents, objections regarding the refund worksheet, and non-verification on a random basis under the Board circular.

Analysis: The refund related to service tax paid by the exporter on GTA services under the reverse charge mechanism, so the transporter was not the person paying service tax and there was no necessity to mention the transporter's registration number on the lorry receipts. The transport documents and shipping bills were found to be correlatable through purchase order numbers and invoice numbers, establishing use of the service for export of goods. The objection based on the difference between the amount proposed by the Range Superintendent and the amount actually rejected was held to be without merit, since the show cause notice and adjudication order supported the rejection amount. The alleged non-sending of the worksheet and the claim that the worksheet related to multiple locations were also found to be frivolous. The requirement of random verification under the Board circular was treated as an administrative instruction and not a legal precondition for denying an otherwise sanctioned refund.

Conclusion: The departmental objections did not justify denial of the refund, and the refund sanction was upheld.

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