https://www.taxtmi.com/caselaws?id=773146 Bombay HC allowed petition challenging rejection of ITC refund for zero-rated export supplies. Revenue authorities incorrectly determined petitioner was mere establishment of foreign recipients, creating agency relationship. Court held petitioner provided design/engineering services on principal-to-principal basis using own resources without foreign control. Agreement explicitly stated petitioner was not agent of foreign recipient. Agency requires third party involvement, but only two parties existed here. Petitioner satisfied all conditions under Section 2(6) IGST Act for export classification. Court granted ITC refund with statutory interest under Sections 54 and 56 CGST Act. en-us Mon, 16 Jun 2025 00:00:00 +0530 Wed, 18 Jun 2025 09:04:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=773146 Bombay HC allowed petition challenging rejection of ITC refund for zero-rated export supplies. Revenue authorities incorrectly determined petitioner was mere establishment of foreign recipients, creating agency relationship. Court held petitioner provided design/engineering services on principal-to-principal basis using own resources without foreign control. Agreement explicitly stated petitioner was not agent of foreign recipient. Agency requires third party involvement, but only two parties existed here. Petitioner satisfied all conditions under Section 2(6) IGST Act for export classification. Court granted ITC refund with statutory interest under Sections 54 and 56 CGST Act. Case-Laws GST Mon, 16 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=773146