𝗖𝗲𝘀𝘁𝗮𝘁 𝗠𝘂𝗺𝗯𝗮𝗶 𝗥𝘂𝗹𝗶𝗻𝗴 𝗼𝗻 𝗘𝘅𝗽𝗼𝗿𝘁 𝗼𝗳 𝗦𝗲𝗿𝘃𝗶𝗰𝗲𝘀 𝗮𝗻𝗱 𝗥𝗲𝗳𝘂𝗻𝗱 𝗖𝗹𝗮𝗶𝗺 📢 𝗧𝗵𝗲 𝗧𝗿𝗶𝗯𝘂𝗻𝗮𝗹 𝗵𝗲𝗹𝗱: Services provided to overseas entities, including after-sales support and engineering support services, qualify as exports under Rule 6A of Service Tax Rules, not intermediary services. Refund allowed.

🔍 𝗙𝗮𝗰𝘁𝘀: 𝗔𝗽𝗽𝗲𝗹𝗹𝗮𝗻𝘁: Idex India Pvt. Ltd. 𝗜𝘀𝘀𝘂𝗲: Services rendered to overseas entities qualify as exports under Rule 6A, allowing the appellant a refund of unutilized input credit.

⚖️ 𝗝𝘂𝗱𝗴𝗲𝗺𝗲𝗻𝘁: The Tribunal ruled that the appellant acted as an independent contractor, not an intermediary. After-sales and engineering support services didn’t involve physical goods, making the place of provision under Rule 3. As the services qualify as exports, the appellant is entitled to a refund of unutilized input credit.

📜 𝗖𝗮𝘀𝗲 𝗜𝗻𝗳𝗼𝗿𝗺𝗮𝘁𝗶𝗼𝗻: 𝗧𝗶𝘁𝗹𝗲: Idex India Pvt. Ltd. vs. Commissioner of CGST, Mumbai East. 𝗢𝗿𝗱𝗲𝗿 𝗗𝗮𝘁𝗲: 9 February 2023. 📜 Services to overseas clients on a principal-to-principal basis qualify as exports, allowing refunds under Rule 5 of CENVAT Credit Rules.