Export-related service tax exemption covers transport of empty containers to the factory when essential for stuffing and shipment.

Exemption notifications for services used in exporting goods were construed to cover GTA service for moving empty containers from the yard to the factory for stuffing and export, because that movement was an essential and integral step in transporting export goods. The phrase "in relation to transport of export goods" was read broadly enough to include ancillary transport necessary to complete the export process, and strict construction did not defeat clear wording. Refund was therefore admissible and the exporter was entitled to the exemption benefit.

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Issues: Whether refund of service tax paid on goods transport agency services used for bringing empty containers from the container yard to the factory for stuffing and export was admissible under the export-related exemption notifications.

Analysis: The relevant notifications exempted services provided to an exporter in relation to transport of export goods from the place of removal to the port, inland container depot, or airport. The expression "in relation to transport of export goods" was held to be wide enough to cover the movement of empty containers to the factory as an integral step in exporting the goods, because export of stuffed containers would not be possible without first bringing the empty containers for loading. The prior consistent view on the same language was followed, and the principle of strict construction of exemption notifications did not assist the revenue where the wording itself created no real doubt.

Conclusion: Refund was admissible, and the appellant was entitled to the benefit of the exemption for the GTA service used to transport empty containers to the factory for export purposes.

Ratio Decidendi: Where exemption language covers services provided in relation to transport of export goods, it extends to ancillary transport of empty containers to the factory when that movement is an essential part of exporting the goods.

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