- (1.) In both these appeals since identical questions of law and facts are involved, they are decided by this common judgment.
(2.) By way of these appeals, the appellant has challenged the judgment and order of the Tribunal whereby the Tribunal has allowed the appeal of the assessee.
(3.) This court while admitting the appeals framed the following question of law:- D.B. Central Excise Appeal No. 22/ 2016 & 47/2016 "1. Whether a service not being delivered outside India and not used outside India can be termed as export in violation of provisions of Export of Service Rules, 2005 and whose effective use and enjoyment was in India, in terms of the Board Circular No.141/10/2011-ITU dated 13.05.2011.";