TMI Blog2015 (12) TMI 1010X X X X Extracts X X X X X X X X Extracts X X X X ..... show that the treatment of the service received as output service is only for the purpose of payment of service tax by the receiver and no other purpose. In view of the above, I find that the submissions by the appellants relating to calculation of turnover for the purpose of calculating admissible refund are correct. - As regards nexus in respect of different services, the learned counsel relied ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ware Service(ITSS), Business Auxiliary Service(BAS) and Business Support Services(BSS). The services are exported to DST Worldwide Services, LLC, USA in terms of a service agreement and to DST Global Solutions Group Services Ltd. in terms of another service agreement. Portion of two refund claims filed by the appellants for the period from October 2009 to March 2010 have been rejected by the Reven ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d have been taken as equal to the export turnover and they had declared only this turnover. Inclusion of amount of service consideration in respect of service received involved for calculating the total turnover is not correct. I find myself in agreement with this submission. The service received is deemed to be output service but it cannot be considered as turnover. The deeming fiction is only fo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ved as output service is only for the purpose of payment of service tax by the receiver and no other purpose. In view of the above, I find that the submissions by the appellants relating to calculation of turnover for the purpose of calculating admissible refund are correct. 3. As regards nexus in respect of different services, the learned counsel relied upon several decisions to submit that ap ..... X X X X Extracts X X X X X X X X Extracts X X X X
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