CUSTOMS, EXCISE AND SERVICE TAX APPELLATE TRIBUNAL CHANDIGARH REGIONAL BENCH - COURT NO. I Service Tax Appeal No. 60568 of 2016 [Arising out of Order-in-Appeal No. 107/ST/Appeal-II/MK/GGN/2016 dated

29.07.2016 passed by the Commissioner (Appeals), Service Tax, Gurgaon]

Commissioner of Service Tax, Delhi-IV ……Appellant Plot No.36-37, Sector-32, Opp. Medanta Hospital, NH-IV, Gurugram, Haryana - 121001 VERSUS M/s BA Call Centre India Pvt. Ltd. ……Respondent DLF Plaza Tower, DLF City Centre, Phase-I, DLF Qutub Enclave, Gurgaon, Haryana-122002 APPEARANCE:

Shri Narinder Singh, Authorized Representative for the Appellant Ms. Priyanshi Chakraborty, Advocate for the Respondent CORAM: HON’BLE MR. S. S. GARG, MEMBER (JUDICIAL) HON’BLE MR. P. ANJANI KUMAR, MEMBER (TECHNICAL)

FINAL ORDER NO.60232/2026 DATE OF HEARING: 10.11.2025 DATE OF DECISION: 09.03.2026 S. S. GARG:

The present appeal, filed by the Revenue, is directed against the Order-in-Appeal dated 29.07.2016 passed by the Commissioner (Appeals) whereby it has been held that call center services provided by the respondent qualify as export of services under Rule 3(2) of the Export of Service Rules, 2005 and consequently, the respondent is eli