https://www.taxtmi.com/caselaws?id=783093 HC held that services supplied by Petitioner to its foreign affiliate qualify as "export of services" under the IGST Act. The Court found that consideration was received in convertible foreign exchange and that Petitioner and the foreign recipient are distinct legal entities, not "mere establishments of distinct persons." Notification No. 04/2019-Integrated Tax, applicable only to pharmaceutical R&D, was held inapplicable as Petitioner provides services to a medical equipment company. Applying the principle of substance over form, HC determined that the place of supply is the foreign recipient's location under Section 13(2) IGST Act. Consequently, the refund rejection order and show cause notices were quashed and refund of unutilized ITC was allowed. en-us Thu, 27 Mar 2025 00:00:00 +0530 Tue, 09 Dec 2025 13:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783093 HC held that services supplied by Petitioner to its foreign affiliate qualify as "export of services" under the IGST Act. The Court found that consideration was received in convertible foreign exchange and that Petitioner and the foreign recipient are distinct legal entities, not "mere establishments of distinct persons." Notification No. 04/2019-Integrated Tax, applicable only to pharmaceutical R&D, was held inapplicable as Petitioner provides services to a medical equipment company. Applying the principle of substance over form, HC determined that the place of supply is the foreign recipient's location under Section 13(2) IGST Act. Consequently, the refund rejection order and show cause notices were quashed and refund of unutilized ITC was allowed. Case-Laws GST Thu, 27 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783093