Refund on GTA services for exports requires verification of document linkage, not outright denial for missing invoice references.

Refund of service tax on GTA services used for export could not be rejected solely because export invoice numbers were not mentioned in lorry receipts and shipping bills. Where the export of goods and the use of taxable services were otherwise undisputed, the issue was one of document linkage and verification rather than denial on merits. The Tribunal directed remand for de novo adjudication so the adjudicating authority could verify the connection between the lorry receipts, export invoices and shipping bills before deciding the refund claim.

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Issues: Whether the refund claim of service tax on GTA services used for export of goods could be denied solely because the export invoice numbers were not mentioned in the lorry receipts and corresponding shipping bills, or whether the matter required verification of the linkage between the receipts, invoices and shipping bills.

Analysis: The refund related to services used in relation to export of goods under the relevant exemption notification. There was no dispute about the export of goods or the use of GTA services. The only objection was the absence of invoice particulars in the lorry receipts and shipping bills. The Tribunal treated the issue as one of verification and relied on the principle that where the export transaction and use of taxable services are otherwise established, the exporter may be permitted to produce evidence to link the documents and the claim should not be rejected outright without verification.

Conclusion: The matter was required to be remanded to the original adjudicating authority for de novo adjudication and verification of the linkage between the lorry receipts, export invoices and shipping bills. The refund claim was not finally rejected on merits.

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