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2016 (2) TMI 580 - CESTAT CHENNAI

2016 (2) TMI 580 - CESTAT CHENNAI - 2016 (43) S.T.R. 576 (Tri. - Chennai) - Refund of unutilized CENVAT credit on export of services under Rule 5 of Cenvat Credit Rules, 2004 (CCR) - Eligible input services - method of calculation of credit to be refunded - prescribed formula - adjudicating authority while computing the value has deducted the value of SEZ exports from the export turn over (numerator) but retained the SEZ export turn over in the total turnover (Denominator). - Held that:- the app .....

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le for the full refund claim. - Decided against the revenue and in favor of assesseee. - ST/278/2010, ST/295/2011, ST/40422/2014 to ST/40425/2014, ST/41019/2015 to ST/41023/2015, ST/551/2011 to ST/554/2011, ST/41015/2015 to ST/41018/2015 - Final Order No. 40247-40265 / 2016 - Dated:- 15-2-2016 - SHRI R. PERIASAMI, TECHNICAL MEMBER AND SHRI P.K. CHOUDHARY, JUDICIAL MEMBER For the Petitioner : Shri Muthu Venkataraman, Adv., Shri Rajaram Ramanan, Consultant, Shri Gopakumar R., Consultant, Shri .....

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.2010, No. 06/2011 dated 04.02.2011, No. 68-71/2013 dated 02.12.2013, No. 05-09/2015 dated 18.02.2015 and No. 01-04/2015 dated 18.02.2015 and the remaining four appeals filed by the Revenue are arising out of one Order-in-Appeal No. No. 39-42/2011 dated 30.08.2011. 2. The brief facts of the case are that the Appellants are rendering software services and the services are exported and also to the domestic clients. The Appellant obtained centralized registration for service tax with the Commission .....

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rejected/restricted the refund claims of the Appellant on the grounds that: * Services related to development of information technology software and maintenance of such software were specifically included as taxable service only from 16.05.2008. * Appellant was engaged in provision of software maintenance service which was not covered under the ambit of Management, maintenance, repair service ( MMRS ) upto 16.05.2008) and hence the same was not taxable up to 16.05.2008. Aggrieved by these order .....

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ice which was not taxable prior to 16.05.08 and the said service is not covered under Management Maintenance and or Repair service . The adjudicating authority also held that services relating to development of information technology software and maintenance of special software are specifically included as taxable services only from 16.05.2008. The appellants are not eligible for refund of CENVAT credit of input services availed on the software maintenance service. Aggrieved by these orders, the .....

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o. OIO No. Refund claimed Refund Granted Refund rejected (under dispute) 33 Feb 2010 40422/2014 68-71/13 02/12/13 176/11 30/06/11 2,82,13,514 86,33,607 1,95,79,907 34 Mar-10 40423/2014 343/11 dt 30/09/11 27912079 8632133 19279946 35 July-10 40424/2014 68-71/13 02/12/13 344/11 dt 30/09/11 3,21,22,060 79,18,828 2,42,02,232 36 Aug-10 40425/2014 389/11 dt 30/11/11 2,45,48,423 97,17,342 1,48,31,081 41 Nov-10 41019/2015 05-09/15 18.02.15 281/12 dt 31.08.12 3,16,82,883 1,05,04,955 2,11,77,928 42 Dec-10 .....

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Z. * that is, in the numerator the total export turnover the adjudicating authority taken only STPI turnover and excluded the SEZ exports and while taking the total turnover (denominator) the adjudicating authority has computed including SEZ exports and accordingly rejected the refund. * The adjudicating authority also excluded the quantum of amount from the refund claim which are otherwise ineligible for which separate show cause notices were issued under CCRs. Aggrieved by this, the appellant .....

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adjudicating authority has restricted the refund on the issue of taxability on the software maintenance and service and also on the computation of total export turnover and total turnover as per the formula. The adjudicating authority issued show cause notices asking to show cause why the refund claim could not be restricted or rejected on the ground that by duly working out the formula for computation of the refund provided under Notification No. 5/2006 and had accordingly rejected the refund .....

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009 dt 07.12.2009 20,89,11,988 47 October 2008 552/2011 408/2009 dt 29.12.2009 4,22,20,331 48 November 2008 553/2011 44/2010 dt. 28.01.2010 6,86,31,605 49 December 2008 554/2011 69/2010 dt. 25.02.2010 5,76,74,059 37 April 2008 to September 2008 41015/2015 01 to 04/2015 dated 18/02/2015 179/2012 dt 17/05/2012 20,70,57,564 38 October 2008 41016/2015 295/2012 dt 11/09/2012 4,20,33,231 39 November 2008 41017/2015 354/2012 dt 02/11/2012 6,80,51,630 40 December 2008 41018/2015 355/2012 dt 02/11/2012 5 .....

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OIA No. 1-4/2015 dated 18.02.2015, the appellants preferred appeals before this Tribunal in ST/41015/15 to 41018/2015. 6. The Ld. Advocate appearing on behalf of the appellants submitted a written synopsis in a tabular form of issues appeal-wise and reiterated the same. In respect of appeal No.s ST/278/10 and ST/295/11, he submits that the Revenue either restricted or rejected on the input service credit on the only ground that the software maintenance service was not taxable under Notification .....

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ice credit on the services utilized under SEZ from April, 2007 to September and October to March 08. He drew attention to page 9 and page 49 of the returns, where the service tax amount on MMRS has been paid at page 21 & 51 where proof of payment of service tax paid both in cash as well as by debiting in CENVAT account under the MMRS service including their services. 7. Without prejudice to the aforesaid submission, they also submitted that even assuming the services were not taxable during .....

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of case laws relied upon in this regard:- He relied on the following decisions: * MPortal India Wireless Solutions Private limited vs. CST Bangalore 2011 TIOL 928 HC-KAR-ST * KPIT Cummins Infosystems ltd. vs. Commissioner of Central Excise, Pune - I 2013- TIOL-931-CESTAT- MUM * APOTEX REASEARCH PVT LTD VS. CC, BANGALORE- CUS 2014 - TIOL -1836- CESTAT BANG * REPRO INDIA LIMITED VS. UNION OF INDIA & ANR 2009 (235) ELT 614 (Bom.) He submitted that in view of the Hon ble High Court and Tribunal .....

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llants operate from various premises across India and have taken a centralized registration for service tax purposes and that all their premises were either STPI or SEZ units from where services are predominantly exported with negligible domestic sales. A sample computation methodology which was under dispute on the manner of arriving at the eligible refund was submitted and further stated that there are three parameters for arriving at the quantum of refund which are as follows: * CENVAT Credit .....

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on services received by SEZ units since they were ab-initio exempt. However, for the purpose of turnover, the Appellant had adopted turnover of SEZ & STPI units, since Rule 5 of CENVAT Credit Rules is for entity as a whole and not for STPI/SEZ separately. They submitted that while applying the formula the lower adjudicating authority deducted the value of SEZ exports from the export turnover (i.e. numerator) but retained the same in the total turnover (i.e. denominator) thereby drastically r .....

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llants claimed the refund by computing the total value wherein it was mentioned that Net CENVAT Credit after deducting those credits for which separate proceedings were initiated was ₹ 1,80,76,926. He mentioned that while this amount was not under dispute, the dispute is on account of Export Turnover and Total Turnover. It was submitted that as per Appellant claim, the value of Export turnover was ₹ 659,81,11,217/- ( including exports from STP and SEZ units), value of domestic turnov .....

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.e. denominator). He submitted that where the adjudicating authority at para 15.2 and 15.4 and at page 77 under para-23 has computed the total turnover (including the value of export services) to be ₹ 678,25,38,893/- then the export value also should be taken as ₹ 659,81,11,217/- 11. Assailing the methodology adopted by the lower adjudicating authority, it was submitted that even if the Department wanted to restrict the export turnover (i.e. numerator) only to the value of services e .....

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aced reliance upon catena of decisions in the context of Section 80HHC and Section 10 A of the Income Tax Act, 1961. He specifically drew our attention to ruling of Hon ble Karnataka High Court in the case of CIT vs. M/s. Tata Elxsi Limited 2011 - TIOL - 684- HC- KAR- IT which in turn placed reliance on various judicial pronouncements and held that there should be uniformity in the ingredients of both numerator and denominator of the formula since otherwise it would produce anomalies or absurd r .....

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otal turnover. A paper book containing the provisions and case laws relied by him for the manner of applying the formula was submitted. 14. The learned authorized representative of the Revenue supported the findings made by the lower authorities in the impugned order in respect of Appeal No. 278/2010 and 295/2011 ( i.e. Sl. No. 31 & 32 of the causelist). She submitted that when software maintenance services were taxable only from 16/05/2008, the question of granting refund in respect of serv .....

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SC) to argue that turnover should include all the turnover of the Appellant as understood in common accounting parlance. She also drew our attention to judicial precedents in the context of SEZ s in the case of Anita Exports vs. Union of India 2015 (320) ELT 743 and mentioned that service tax authorities do not have oversight of the activities performed in SEZ and only SEZ authorities have the same. Reliance was placed upon the following judicial precedents and mentioned that supplies to SEZ cou .....

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f CENVAT Credit which were excluded from these proceedings. 15. On the rejoinder, the Advocates appearing for the Appellant re-iterated the case laws relied upon by them for Appeal No. 278/2010 and 295/2011. With respect to the manner of application of the formula, they submitted that Supreme Court in the case of CIT vs. Punjab Stainless Steel relied upon by the Department was in fact favorable to them. They relied upon the operative part of the Supreme Court ruling which held that the turnover .....

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VAT Credit, the refund ought to have been granted in accordance with the claim made by the Appellant rather than restricting the same in a manner which is not the intention of the legislature. Further, it was also submitted that the Appellant did not avail of any CENVAT Credit pertaining to the SEZ operations and that is what is more critical since the refund that is granted is of CENVAT Credit and not that of turnover. 17. As regards, other precedents relied upon by Department representative, t .....

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CIT Vs. Sudarshan Chemical Industries Ltd.-2003 -TIOL-95-HC-MUM-IT 5. CIT Vs. Chloride India Ltd. -2003 (130) Taxman 352 (Cal.) 18. We have carefully considered the submissions of both sides and perused the records and the grounds of appeal in respect of both the assesse appeals as well as Revenue appeals. The short issue involved in this case relates to rejection of refund on input service credit utilized in the export of services and refund claimed under Rule 5 of CCR. The adjudicating author .....

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ose to discuss the first issue relating to the input services utilized for the export of service. On perusal of the records, ST-3 returns, we find that the appellant is a software firm engaged in the business of software development and obtained centralized service tax registration under LTU Commissionerate and discharging service tax on the software services rendered to local customers and also exported software services. There is no dispute on the payment of service tax by the appellant on the .....

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through their CENVAT account and also they have paid education cess and higher education cess of ₹ 1,73,457/- in cash and ₹ 24,329/- through CENVAT and ₹ 5,351/- in cash and ₹ 12,120/- through CENVAT account respectively and the appellant has claimed refund of service tax paid on input service which was used in output service. From the above, it is very clear that the Revenue cannot adopt two standards, when the appellant paid service tax under MMRS the same was accepted .....

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he identical issue on the software consultancy service exported during the relevant period and allowed the appeal by following the Honble High Court of Karnataka decision in the case of mPortal India Wireless Solutions Pvt. Ltd. Vs. CST, Bangalore reported in 2011-TIOL-928-HC-KAR-ST. The relevant portion of the said decision is reproduced as under:- :5.1 From the records of the case it is seen that during the impugned period the appellant had exported the following goods/services: (i) Software .....

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me became taxable under service tax only w.e.f. budget 2008 when Information Technology Software Service' was brought under the tax net for the first time. Therefore, as far as these two services are concerned, they were not a taxable service during the impugned period. 5.3 Nevertheless, they were exempted services as defined in Rule 2(e) of the CENVAT Credit Rules, 2004 as per which: "'exempted services' means taxable services which are exempt from the whole of the service tax .....

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pressions provider' and provided' shall be construed accordingly." Under Rule 5 of the CENVAT Credit Rules: "where any input or input service is used in the manufacture of final product which is cleared for export under bond or letter of undertaking, as the case may be, or used in the intermediate product cleared for export, or used in providing output service which is exported, the CENVAT credit in respect of the input or input service so used shall be allowed to be utilised b .....

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tion NO. 5/2006-CE (.N.T.) dated 14/03/2006 has been issued. Rule 6 of CENVAT Credit Rules, 2004 deals with obligation of the manufacturer of dutiable and exempted goods and provider of taxable and exempted services. Under Rule 6(3)(c), the provider of output service shall utilize credit only to the extent of an amount not exceeding 20% of the amount of service tax payable on taxable output service. In the present case, the services provided by the appellant and exported is not a taxable output .....

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9;ble High Court of Karnataka in mPortal India Wireless Solutions P. Ltd. (supra) case, in a similar situation, held as follows: "6. The assessee is a 100% export oriented unit. The export of software at the relevant point of time was not a taxable service. However, the assessee had paid input tax on various services. According to the assessee a sum of ₹ 4,36,985/- is accumulated cenvat credit. The Tribunal has categorically held that even though the export of software is not a taxabl .....

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ed counsel appearing for both parties were unable to point out any provision in the cenvat credit rules which impose such restriction. In the absence of a statutory provision which prescribes that registration is mandatory and that if such a registration is not made the assessee is not entitled to the benefit of refund, the three authorities committed a serious error in rejecting the claim for refund on the ground which is not existence in law. Therefore, said finding recorded by the Tribunal as .....

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ax being a destination based consumption tax, in the case of exports there should not be any tax burden and the tax burden, if any, is to be imposed by the Government of the country where the services are consumed. Otherwise, it would render the exports of software uncompetitive. Keeping in view of above policy objective of the government, it is appropriate to hold that the appellants are eligible for the refund of the amount claimed by them of ₹ 2,14,45,060/- during the impugned period on .....

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clearly established that the appellants have paid the service tax on MMRS and availed credit. The above decision was followed by the co-ordinate Bangalore Bench of the Tribunal in the case of Apotex Research Pvt. Ltd. Vs. CC, Bangalore (supra). The various Tribunal s decisions relied by the Revenue are not applicable and distinguishable to the facts of the present case. 20. Further the Tribunal Mumbai Bench in the case of CCE, Pune Vs. Barclays Technology Centre (I) Pvt. Ltd - 2014 TIOL-2641-CE .....

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rt of services during the relevant period. By respectfully following the Hon ble High Court decision and the Tribunal decision referred above, we have no hesitation to hold that the appellants are eligible for refund under Rule 5 of CCR on the input services used in the export of service. Accordingly, impugned orders No.15/10 and No.6/11 (in appeal No. ST/278/2010 and ST/295/11) are liable to be set aside to that extent of rejection of refunds. Both the appeals are allowed with consequential rel .....

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to the total turnover for the given period to which the claim relates i.e. Maximum refund ( Total CENVAT credit taken on input services during the given period W export turnover w Total turnover. Explanation : For the purposes of condition no. 5, - 1. Export turnover shall mean the sum total of the value of final products and output services exported during the given period in respect of which the exporter claims the facility of refund under this rule. 2. Total turnover means the sum total of t .....

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total turnover, the appellants have computed total turnover of both SEZ and STPI units as the appellants being one entity. Whereas, it is seen the adjudicating authority while computing the value has deducted the value of SEZ exports from the export turn over (numerator) but retained the SEZ export turn over in the total turnover (Denominator). The appellants contended that the adjudicating authority when deducting the value of SEZ exports from the turnover, ought to have deducted the same from .....

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4. On perusal of the record, it transpires that the first appellate authority has clearly recorded the factual matrix of the case as to there being no dispute that the appellant had rendered export of services and has availed CENVAT credit of the input services received by him. Revenue is only disputing the quantum of the refund claim which has been sanctioned to the appellant based upon the finding that the provisions of Rule 5 of the CENVAT Credit Rules, 2004 contemplates for sanctioning of th .....

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the export turnover of the goods but they want to include the CENVAT credit in the total turnover of export of goods. This view which has been propounded by the ld. Departmental Representative and the appeal of the department is canvassing the findings expressed by the Adjudicating Authority. 1. I find that this view is incorrect as, if the revenue wants to reduce the value of the invoices from the export turnover, the same also should be removed from the total turnover of the export. I find th .....

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s, 2005, whether the payment is received or not;" From this definition it is clear that for the purposes of new Rule 5 of the CCR, receipt of payment is immaterial and only the actual export of service by way of its provision & issuance of invoice remain the relevant criteria. As per the first proviso to Rule 5(2) of the CCR, refund in respect of services exported could be made under the old Rule 5 of the CCR within a period of one year, i.e. upto 31.03.2013. In other words, for the exp .....

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ar 12-02, both dated 30-03-2012, in the present refund claim on the ground that payments in respect of the same were received on 11-04-2012. However, the export of services covered by the said invoices had been completed prior to 31-03-2012, as reflected in the date of issuance of the said invoices. As provisions of new Rule 5 of the CCR are applicable to the exports made on or after 01-04-2012, the exports covered said invoices issued prior to 01-04-2012 have to be excluded from the present ref .....

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Therefore, the 'export turnover' would be equal to the 'total turnover', in terms of clause (E) of Rule 5(1) of the CCR. Accordingly, the figures of 'Export Turnover of Services' and Total Turnover' come to ₹ 11,95,79,832/- each. 17. In view of the above discussions, I find that the admissible refundamount needs to be re-calculated. The same is done as under: Export turnover of services = 11,95,79,832/- Total Turnover= 11,95,79,832/- Net CENVAT Credit=41,52,535/ .....

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High Court in the case of CIT & Others Vs. Tata Elxsi Ltd. & Others reported in 247 CTR- 334, in respect of computation of deduction under Section 10 (A) of IT Act, dealt the identical issue of computation of export turn over and total turnover and dismissed the revenue appeal and upheld the Tribunal order. The relevant portion of the said order is reproduced as under:- 10. The Bombay High Court had an occasion to consider the meaning of the word total turnover in the context of Section .....

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ness of the undertaking in computing the profits derived from export The formula for computation of the deduction under Section 10-A would be as under:- Profits of the business x export turnover/ Total turnover From the aforesaid judgments, what emerges is that, there should be uniformity in the ingredients of both the numerator and the denominator of the formula, since otherwise it would produce anomalies or absurd results. Section 10-A is a beneficial section. It is intended to provide incenti .....

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o be derived from the total business income of the assesse, whereas in Section 10-Am the export profit is to be derived from the total business of the undertaking. Even in the case of business of an undertaking, it may include export business and domestic business, in other words, export turnover and domestic turnover. The export turnover would be a component or part of a denominator, the other component being the domestic turnover. In other words, to the extent of export turnover, there would b .....

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enominator cannot be different. Therefore, though there is no definition of the term total turnover in Section 10-Am there is nothing in the said Section to mandate that, what is excluded from the numerator that is export turnover would nevertheless form part of the denominator. Though when a particular word is not defined by the legislature and an ordinary meaning is to be attributed to the same, the said ordinary meaning to be attributed to such word is to be in conformity with the context in .....

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total turnover, such an interpretation would have expressly stated so. If they have not chosen to expressly define what the total turnover means, then, when the total turnover includes export turnover, the meaning assigned by the legislature to the export turnover is to be respected and given effect to, while interpreting the total turnover which is inclusive of the export turnover. Therefore the formula for computation of the deduction under Section 10-A, would be as under: Export turn over Pro .....

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the value of SEZ exports from the export turn over (numerator) and retained the same in the total turnover (denominator) which has resulted in the anomaly and the reduction in the quantum of refund. The Clause 5 of the Notification No. 5/06 dated 14.3.06, clearly stipulates that the formula has to be applied only for the activity to which the claim relates and it is for the entity as a whole. Accordingly, we hold that when the revenue proceeded to include the value of SEZ exports in computing th .....

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luded in the export turnover (numerator). Accordingly, the appellants are eligible for the full refund claim in appeal Nos. ST/40422 to 40425/14 and ST/41019 to 41023/15, and the impugned orders OIA Nos. 68 to 71 dated 02,12,2013 OIA Nos. 05 to 09/2015 dated 18.02.2015, are set aside to that extent. 26. In respect of Revenue appeals in ST/551 554/2011 filed against the OIA No. 39 to 42/11 dated 30.08.2011, the Commissioner (Appeals) has set aside that portion of the original order rejecting the .....

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sesses appeals and held that the appellants are eligible for full refund of input services credit on the export of service as well as on computation of export turnover vis-vis total turnover as per the formula under clause 5 of Notification No. 5/2006 dated 14.03.2006, the same is applicable to the revenue appeals. Therefore, we do not find any infirmity in the impugned orders passed by the Commissioner (Appeals) and we uphold the impugned orders and revenue appeals are rejected. 27. As regards .....

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