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    <title>2025 (3) TMI 1526 - BOMBAY HIGH COURT</title>
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    <description>Services provided by the petitioner to foreign universities were not intermediary services because, read as a whole, the export of services definition, the recipient test and the place of supply rules showed that the service was rendered to the foreign universities, not to students in India. Applying the reasoning in Ernst &amp; Young Ltd. and the relevant circular dated 20 September 2021, the activity was treated as an export of services. On that basis, the petitioner was entitled to refund of GST paid, subject to receipt of consideration in foreign currency.</description>
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