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The text addresses whether cross border 'unbilled shipments' qualify as zero rated supply under the IGST regime when no convertible foreign exchange is received. It highlights a statutory tension between liability under Section 7 CGST and entitlement to zero rating under Section 16(1) read with the export definition in Section 2(6) IGST, which requires receipt of consideration in convertible foreign exchange; non receipt may sustain tax liability yet deny zero rating. The court confined adjudication to that interpretative question, issued notice, deferred the refund claim, invited the CBIC to state or clarify its position, and treated the petitioner's factual stance as a representation.
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