Refund jurisdiction for export of service follows where the service was provided and the taxable event arose, not where foreign exchange was realised.

Foreign exchange realisation at Mumbai did not change the jurisdictional position because export of service was complete once the foreign exchange was received in India. The Mumbai and Coimbatore units were not treated as distinct for this purpose, and since the service was provided in Coimbatore and the taxable event arose there, the Coimbatore authority was the proper forum to entertain the refund claim. The Revenue's challenge to Coimbatore jurisdiction therefore failed.

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Issues: Whether the refund application was required to be filed at Mumbai because the foreign exchange was realized there, or whether the Coimbatore authority had jurisdiction since the service was provided there and the taxable event occurred there.

Analysis: Realization of foreign exchange at Mumbai did not alter the legal position, because the export of service was complete once the foreign exchange came to India. The respondent's Mumbai and Coimbatore units were not to be treated as distinct for this purpose. Since the service was provided in Coimbatore and the taxable event arose there, the Coimbatore authority was the proper forum to entertain the refund claim.

Conclusion: The Coimbatore authority had jurisdiction to entertain the refund application, and the Revenue's challenge failed.

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