Export service tax rebate turns on practical transport correlation, but each claimed service needs independent nexus proof.

Rebate of service tax on export-related services was examined on a service-by-service basis. For GTA transport from factory to port, a broad factual correlation between transport evidence, tax payment and exported quantity was treated as sufficient, so the rebate was allowed. For stockyard rent, the claim failed because the material did not clearly identify the input service or establish nexus with export of goods, so that rebate was rejected. The note indicates that export rebate claims require practical evidence of linkage for transport services, but each separate service must still be independently supported by facts and nexus.

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Issues: (i) Whether rebate of service tax paid on GTA service used for transportation of export goods from the factory to the port was admissible. (ii) Whether rebate of service tax paid on stockyard rent was admissible.

Issue (i): Whether rebate of service tax paid on GTA service used for transportation of export goods from the factory to the port was admissible.

Analysis: The goods were transported directly from the factory to the port, the quantity cleared and the service tax paid on GTA service were not in dispute, and the only objection was that the exporter's invoice details were not specifically mentioned in the lorry receipts. A broad correlation between the transportation evidence, the service tax paid and the quantity exported was sufficient in the facts of the case, consistent with the earlier final order relied upon.

Conclusion: The rebate claim of Rs. 1,35,802/- was admissible and was allowed in favour of the assessee.

Issue (ii): Whether rebate of service tax paid on stockyard rent was admissible.

Analysis: The materials placed did not identify the specific input service with clarity and did not establish any nexus between the service on which rebate was claimed and the export of goods. The claim was therefore unsupported on facts and did not satisfy the basis required for rebate.

Conclusion: The rebate claim of Rs. 8,499/- was not admissible and was rejected.

Final Conclusion: Relief was granted only in respect of the GTA-service rebate, while the claim relating to stockyard rent failed for want of proof of nexus and admissibility.

Ratio Decidendi: For rebate of service tax on export-related services, a practical broad correlation between transport evidence, service tax payment and exported quantity may suffice, but the claimant must independently establish the nexus and factual basis for each rebate claim.

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