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    <title>2020 (12) TMI 1329 - COMMISSIONER OF GST (APPEALS), CHANDIGARH</title>
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    <description>The Commissioner of GST (Appeals), Chandigarh rejected the appellant&#039;s refund claim for tax paid on alleged export of services. While the refund application was filed within the two-year limitation period under Section 54(1) of CGST Act, 2017, the Commissioner held that the appellant&#039;s services constituted intermediary services under Section 2(13) of IGST Act. The appellant provided promotional and marketing services to foreign universities as their representative in India, not as an independent service provider. Under Section 13(8)(b) of IGST Act, the place of supply for intermediary services is the location of the service provider, which was India. Since the place of provision was not outside India, the services did not qualify as export of services under Section 2(6) of IGST Act, making the refund claim inadmissible.</description>
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      <description>The Commissioner of GST (Appeals), Chandigarh rejected the appellant&#039;s refund claim for tax paid on alleged export of services. While the refund application was filed within the two-year limitation period under Section 54(1) of CGST Act, 2017, the Commissioner held that the appellant&#039;s services constituted intermediary services under Section 2(13) of IGST Act. The appellant provided promotional and marketing services to foreign universities as their representative in India, not as an independent service provider. Under Section 13(8)(b) of IGST Act, the place of supply for intermediary services is the location of the service provider, which was India. Since the place of provision was not outside India, the services did not qualify as export of services under Section 2(6) of IGST Act, making the refund claim inadmissible.</description>
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