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The HC held that the question whether the recipients of the petitioner's manpower services fall within the exemptions under the impugned notifications must be determined on facts and by reference to the status of each recipient, and is for the Appellate Authority to decide. Noting that the petitioner has not collected GST from its clients and given the factual nature of the dispute, the HC permitted the petitioner to file an appeal under Section 107 of the CGST Act by 10 July 2025. The Appellate Authority is directed to consider the factual issues and to determine the quantum of any pre-deposit payable. Petition disposed.
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