Jurisdictional objections must be raised early, while minor export refund document defects do not automatically defeat eligibility.

A jurisdictional objection that was not raised before the first appellate authority could not be introduced for the first time before the Tribunal. In the refund context, minor documentary discrepancies, including address variations, did not by themselves defeat a claim for Service Tax refund on input services used for exports when eligibility was otherwise established in principle. The discussion also notes that supporting proof of payment and export realisation could still be required before the adjudicating authority for processing the refund. The Revenue's challenge was therefore rejected, and the assessee's refund entitlement was left intact subject to furnishing the required proof.

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Issues: (i) Whether the Revenue could raise a jurisdictional objection for the first time before the Tribunal. (ii) Whether the assessee was entitled to refund of Service Tax on input services used for export despite minor documentary discrepancies and pending production of payment proof and export realisation proof.

Issue (i): Whether the Revenue could raise a jurisdictional objection for the first time before the Tribunal.

Analysis: The jurisdictional objection was required to be taken at the first instance before the lower appellate authority. As it was not raised there, it could not be entertained at the Tribunal stage.

Conclusion: The jurisdictional objection was rejected and decided against the Revenue.

Issue (ii): Whether the assessee was entitled to refund of Service Tax on input services used for export despite minor documentary discrepancies and pending production of payment proof and export realisation proof.

Analysis: The refund claim was examined on the documents relating to export and input-service utilisation. Minor discrepancies such as the mention of corporate or branch office address did not defeat the claim. The appellate authority had accepted the claim in principle and only directed production of payment proof and proof of export realisation before the adjudicating authority for grant of refund.

Conclusion: The refund claim was held to be maintainable in principle and the Revenue's challenge was rejected.

Final Conclusion: The appeal failed, and the assessee's entitlement to refund was left intact subject to compliance with the directions for furnishing supporting proof before the adjudicating authority.

Ratio Decidendi: A jurisdictional objection not raised before the first appellate authority cannot be agitated for the first time in further appeal, and minor documentary defects do not by themselves justify denial of refund where eligibility is otherwise established in principle.

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