Refund correlation under export-service notification requires broad matching, and the dispute was remanded for fresh adjudication.

Refund under Notification No. 41/2007-ST was examined against the requirement of correlation between input services and exports. The CBEC circular on export-service refunds indicated that strict one-to-one matching was not required and that a broad correlation between input services, service tax paid, and exports could suffice. Because the adjudicating authority had not made specific findings on the circular's applicability and the record was incomplete, the matter was remanded for fresh adjudication with an opportunity to produce documents and be heard.

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Issues: Whether the refund claim under Notification No. 41/2007-ST dated 06.10.2007 required one-to-one correlation between input services and exports, and whether the matter should be remanded for consideration of the CBEC circular clarifying the extent of correlation required.

Analysis: The refund claim arose in the context of export-related services under Notification No. 41/2007-ST. The record showed a dispute on correlation between duty-paid documents, input services, and export documents. The relevant CBEC Circular No. 120/01/2010-ST dated 19.01.2010, which was relied upon below, indicated that exporters faced difficulty in establishing strict one-to-one correlation and that only a broad correlation between input services, service tax paid, and exports was required. The Adjudicating Authority had not recorded specific findings on the applicability of that circular, and the record before the Tribunal was insufficient to decide the extent of correlation on merits.

Conclusion: The matter required fresh adjudication in light of the CBEC circular, and the refund dispute was remanded to the Adjudicating Authority with an opportunity of personal hearing and production of relevant documents.

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