https://www.taxtmi.com/caselaws?id=797927 Business Auxiliary Services falling within Category III under the Export of Services Rules, 2005 are assessed primarily by the location of the service recipient. Services provided in relation to business or commerce to a recipient outside India qualify as exports where the foreign business receives the benefit, even if underlying activities occur in India. Denial of accumulated Cenvat credit refund under Rule 5 on the basis that such services are non-exported requires a consistent position that includes service-tax recovery proceedings under Section 73 of the Finance Act, 1994. Refund denial based solely on contrary treatment of the same services as domestic taxable services is unsustainable. en-us Mon, 24 Aug 2026 00:00:00 +0530 Mon, 31 Aug 2026 09:25:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797927 Business Auxiliary Services falling within Category III under the Export of Services Rules, 2005 are assessed primarily by the location of the service recipient. Services provided in relation to business or commerce to a recipient outside India qualify as exports where the foreign business receives the benefit, even if underlying activities occur in India. Denial of accumulated Cenvat credit refund under Rule 5 on the basis that such services are non-exported requires a consistent position that includes service-tax recovery proceedings under Section 73 of the Finance Act, 1994. Refund denial based solely on contrary treatment of the same services as domestic taxable services is unsustainable. Case-Laws Service Tax Mon, 24 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797927