Cross-border service tax liability before 18.04.2006 was excluded for services received outside India, with no substantial legal issue arising.

Services received outside India from a non-resident were not subject to service tax for the period before 18.04.2006, including technical advice and consulting engineering services. The Court treated this position as settled by departmental circulars and binding precedents, and therefore found no disputable legal issue requiring further examination. On that basis, no substantial question of law arose from the Revenue's challenge, and the exoneration from service tax remained undisturbed.

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Issues: Whether service tax was leviable on services received outside India prior to 18.04.2006, and whether the Revenue's appeal raised any substantial question of law.

Analysis: The demand related to technical advice and consulting engineering services, but the controlling legal position was that services rendered by a non-resident and received outside India prior to 18.04.2006 were not exigible to service tax. The Court also noted the accepted position reflected in the departmental circular and the binding precedents relied upon, and held that in view of this undisputed legal position there was no need to examine delay or any further controversy.

Conclusion: Service tax was not leviable on the disputed services for the relevant period, and no substantial question of law arose.

Final Conclusion: The Revenue's challenge failed and the dismissal of the appeals left the exoneration from service tax intact.

Ratio Decidendi: Services received outside India prior to the commencement of the charging provision for such cross-border services were not subject to service tax, and in the absence of any disputable legal issue no substantial question of law arose.

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