Verizon India eligible for refund of Cenvat on Services to Verizon USA rendered as principal service provider

Verizon India Pvt. Limited Vs Commissioner of Service Tax (CESTAT Delhi) The case of Revenue is that the location of service provider/appellant is in India and further in terms of Rule 9 of POPS, the service provided, being intermediary services, the location of the service provider under Rule 9 of POPS, shall be the place of provision of services, provided to Verizon US. Further, case of Revenue is that as location or place of provision of service is in India, it does not amount to export of service and accordingly, the appellant is not eligible for export benefits (Refund of Input tax ) and ...