No Service tax payable if benefit of service accrued to the foreign clients outside the Indian territory

In the instant case, the services rendered by the appellant were consumed abroad where the appellant’s clients used the service of inspection/test/analysis to decide whether the goods intended to be imported by them from India conformed to the requisite specifications and standards. In other words, the benefit of the service accrued to the foreign clients outside the Indian territory .

By no stretch of imagination can it be said that there was no export of service. The services, in question,

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