Export service tax refund cannot be denied for lack of strict one-to-one correlation when broad nexus is shown.

Refund of service tax on export-related input services under Notification No. 41/2007-S.T., as amended, could not be denied merely because the exporter showed only broad co-relation, not strict one-to-one linkage, between the services, export consignments and tax payment. The governing circular recognised practical difficulty in proving exact correlation and accepted self-certification or chartered accountant certification, supported by basic document scrutiny, where the nexus with exports was broadly established. On the facts, the record supported such a broad co-relation for GTA and other services used for exported iron ore fines, and the Revenue failed to justify rejection on a stricter standard. The refund claim was therefore admissible and consequential relief followed.

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Issues: Whether refund of service tax on specified input services used for export under Notification No. 41/2007-S.T., as amended, was admissible when the exporter could establish only broad co-relation between the services, the export consignments and the tax paid.

Analysis: The refund scheme under Notification No. 41/2007-S.T., as amended by Notification No. 3/2008-S.T., required co-relation of input services with exports, but the governing circular clarified that exporters faced practical difficulty in proving strict one-to-one co-relation. The circular recognized that self-certification by the exporter or certification by a chartered accountant, together with basic scrutiny of documents, was sufficient where the nexus between input services and exports could be broadly established. In the facts found, the record supported broad co-relation of GTA and other services with the exported iron ore fines, and the Revenue did not produce material to justify rejection on a stricter standard.

Conclusion: The refund could not be denied for want of strict one-to-one correlation, and the assessee was entitled to the refund claim.

Final Conclusion: The impugned appellate order was unsustainable, the original refund sanction was restored, and the appeal succeeded with consequential relief.

Ratio Decidendi: Where the refund scheme for export-related service tax permits practical verification through circular guidance, broad co-relation supported by self-certification or chartered accountant certification is sufficient, and refund cannot be refused merely for absence of strict one-to-one documentation.

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