https://www.taxtmi.com/caselaws?id=446059 Services supplied to an overseas group entity qualified as export of services because the recipient was outside India, invoices were raised directly on the foreign entity, consideration was received in convertible foreign exchange, and the work involved original research, development and support on the supplier's own account. The arrangement was not mere facilitation between two parties, so intermediary treatment did not apply. Refund rejection was also unsustainable because part of the claim was denied without notice, and the revenue could not adopt an inconsistent stand after the earlier factual position had attained finality. The refund orders were quashed and refund for the relevant period was allowed. en-us Mon, 24 Apr 2023 00:00:00 +0530 Wed, 30 Jul 2025 15:01:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=446059 Services supplied to an overseas group entity qualified as export of services because the recipient was outside India, invoices were raised directly on the foreign entity, consideration was received in convertible foreign exchange, and the work involved original research, development and support on the supplier's own account. The arrangement was not mere facilitation between two parties, so intermediary treatment did not apply. Refund rejection was also unsustainable because part of the claim was denied without notice, and the revenue could not adopt an inconsistent stand after the earlier factual position had attained finality. The refund orders were quashed and refund for the relevant period was allowed. Case-Laws GST Mon, 24 Apr 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=446059