Export refund claims may rely on broad documentary correlation where exact invoice matching is impractical in bulk cargo cases.

Export-linked service tax refund under Notification No. 41/2007-S.T. may not be denied solely because the exporters' invoice details are absent from lorry receipts, where transport records, shipping documents and a Chartered Accountant's certificate provide a workable correlation between the goods exported and the GTA services used. The governing circular recognises practical difficulty in exact one-to-one matching and accepts broad correlation in such export cases. In bulk cargo exports, strict insistence on invoice particulars in every lorry receipt is unnecessary, and substantial documentary compliance is sufficient to support the refund claim.

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Issues: Whether refund of service tax paid on GTA services used for export of goods was admissible when the exporters' invoice details were not mentioned in the lorry receipts, and whether the claim could be sanctioned on a broad correlation supported by certification and export documents.

Analysis: The refund claim arose under Notification No. 41/2007-S.T. as amended, which required correlation between the exported goods and the taxable services used. The record showed that the export invoices were not reflected in the lorry receipts, but the claim was supported by transport documents, shipping documents, and a Chartered Accountant's certificate correlating quantity transported with quantity exported. The circular issued by the Board recognized practical difficulty in one-to-one correlation and indicated that a broad correlation of input services and service tax paid with exports would suffice. In the peculiar facts of bulk cargo exports, strict insistence on invoice details in each lorry receipt was not warranted.

Conclusion: The refund could not be denied merely for absence of exact invoice particulars in the lorry receipts, and the assessee was entitled to the refund on broad correlation.

Ratio Decidendi: Where export-linked refund under the notification is supported by documentary evidence and the governing circular permits broad correlation, substantial compliance is sufficient and a rigid one-to-one matching requirement cannot defeat the refund claim.

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