Dismissing the appeal of the Revenue the Court held that  the definition of the expression “services” is not provided in the 1961 Act. A perusal of the definition of “services”, would show that, inter alia, tradable services, which are prescribed by the Central Government for the purposes of the 2005 Act, are included in the definition. What those tradable services which are alluded to in section 2(z)(ii) are referred to in rule 76 of the 2006 Rules, with the Explanation. A plain reading of the Explanation would show that trading for the purposes of the Second Schedule of the 2005 Act means import for the purposes of re-export. Undoubtedly, the 2005 Act and rule 76 point in the direction that the expression “services” means services which are offered by way of re-export of articles that are imported into the country. If there was any doubt as regards this aspect of the matter, it is clarified in Instruction No. 4 dated May 24, 2006 issued by the Government of India, Ministry of Commerce and Industry, Department of Commerce. The Instruction has been adopted by the Export Promotion Council in its Circular No. 17 dated May 29, 2006. Likewise, after rule 76 was inserted in the 2006 Rules, the Export Promotion Council for export oriented undertakings and special economic zone units issued another circular dated November 16, 2006. Accordingly having regard to this intrinsic evidence available both in the 2005 Act and Rules, it was always intended that the deduction under section 10AA of the 1961 Act will also be available qua those articles which, upon import to the unit located in special economic zone, were thereafter re-exported. (AY.2010-11)