The HC allowed the petition, holding that the impugned services...

The HC allowed the petition, holding that the impugned services qualify as exports rather than intermediary supplies for GST purposes. The court concluded the petitioner performed services directly for a single overseas contracting party under a specific contractual arrangement, and absent a tripartite relationship the statutory definition of 'intermediary' is not satisfied. Applying the reasoning of co-ordinate appellate and higher judicial authorities, the HC held that the place of provision lies outside the taxable territory and the supply constitutes export of services. Consequently, the respondents' contrary classification was set aside and the petitioner's treatment as an exporter was upheld.