The SC affirmed the impugned CESTAT and High Court orders,...

The SC affirmed the impugned CESTAT and High Court orders, dismissing the appeals. The Court held that the CESTAT correctly construed Rule 3 regarding the expressions "delivered outside India and used outside India" and "provided from India and used outside India," and appropriately evaluated the contractual relationship between service provider and recipient to determine export of services. The determinations were held to be findings of fact devoid of perversity and not amenable to re-determination on appeal. Reliance on prior authoritative decisions was permitted. Given the factual nature of the conclusions and the absence of any legal error, there was no basis to interfere, and the appeals were dismissed.