SEZ service tax exemption applied where identical later-period demands were covered by the appellant's earlier ruling.

Services rendered to units in a Special Economic Zone were treated as exempt from service tax under the SEZ statutory scheme, following the appellant's earlier case on the same issue. The later demand arose on identical factual and legal allegations for a subsequent period, so the prior ruling governed the controversy. On that basis, the confirmation of service tax was set aside and the demand could not be sustained.

---

---

Issues: Whether services rendered to units in a Special Economic Zone were exempt from service tax under the Special Economic Zone Act, 2005.

Analysis: The dispute concerned service tax demand for the subsequent period and turned on the same factual and legal controversy already decided in the appellant's own earlier case. That earlier decision had held that the services rendered to SEZ units were exempt from service tax under the statutory scheme governing SEZ operations. Since the present demand arose on identical allegations for a later period, the prior decision governed the controversy.

Conclusion: The demand could not be sustained and the confirmation of service tax was set aside in favour of the appellant.

---