Consolidated CA certificate can satisfy refund notification requirements for service tax, subject to verification of supporting invoices.

Refund of service tax under Notification No. 41/2007-S.T. could not be denied merely because the assessee furnished a consolidated Chartered Accountant certificate instead of separate certification for each invoice. The certification requirement was treated as satisfied in substance where the certificate identified the invoices and supported the export-use nexus for the services. However, the original authority was still required to verify the invoice numbers against the supporting records, and any invoice not produced or not covered by the certificate would not qualify for refund. The objection to refund therefore failed, subject to verification of documents and recomputation for any uncovered invoices.

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Issues: Whether refund of service tax under Notification No. 41/2007-S.T. dated 6-10-2007 could be denied merely because the assessee produced a consolidated Chartered Accountant certificate instead of separate certification of each invoice.

Analysis: The notification was intended to ensure that the services for which refund was claimed were used for export purposes and had in fact been paid for. A consolidated certificate containing details of the invoices could satisfy the requirement of certification in substance, and the objection that each invoice must be separately certified was held to be unsustainable. At the same time, the invoice numbers mentioned in the certificate had to be verified by the original authority, and any invoice not produced or not covered by the certificate would not qualify for refund.

Conclusion: The consolidated certificate was accepted as meeting the notification requirement in principle, but the matter required verification of the supporting documents and recomputation of refund for any invoices not duly covered.

Final Conclusion: The legal objection to the refund claim failed, and the matter was sent back for document verification and consequential adjustment of the refund.

Ratio Decidendi: A procedural certification requirement in a refund notification may be satisfied by a consolidated certificate if it substantively establishes the invoices and export-use nexus, subject to factual verification of the underlying documents.

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