Export of service treatment for Indian services rendered to foreign principal customers supports refund eligibility and rejects service tax liability.

Services performed in India for customers of a foreign principal, where the provider acted on behalf of that foreign principal, were treated as export of taxable service for the relevant period. Applying its earlier ruling, CESTAT Ahmedabad held that such activity fell within the export category and was not liable to service tax. On that basis, the refund claim was maintainable and admissible, and the Revenue's appeal failed.

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Issues: Whether the services rendered by the respondent for the customers of its foreign principal amounted to export of service so as to entitle it to refund of service tax.

Analysis: The respondent provided services in India for the customers of a principal located outside India and acted on behalf of that foreign principal. The Tribunal followed its earlier decision holding that such activity falls within the scope of export of taxable service and is not liable to service tax for the relevant period. On that basis, the refund claim was held to be maintainable.

Conclusion: The services were export of service and the refund was admissible; the Revenue's appeal failed.

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