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    <title>2025 (12) TMI 1779 - KARNATAKA HIGH COURT</title>
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    <description>The dominant issue was whether services rendered to an overseas recipient constituted &quot;intermediary services&quot; under s.2(13) IGST Act, attracting GST in India, or &quot;export of services&quot; under s.2(6) IGST Act. Relying on its earlier decision in a materially identical fact situation, the HC held that the service provider acted as an independent service provider and not as an intermediary; consequently, the services qualified as export, and GST demand premised on &quot;intermediary&quot; characterization could not be sustained, leading to quashing of the impugned show cause notice to the extent of the specified audit objection. For the remaining audit objections, the petitioner was permitted to file replies with documents and the department was directed to proceed in accordance with law.</description>
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      <title>2025 (12) TMI 1779 - KARNATAKA HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=784239</link>
      <description>The dominant issue was whether services rendered to an overseas recipient constituted &quot;intermediary services&quot; under s.2(13) IGST Act, attracting GST in India, or &quot;export of services&quot; under s.2(6) IGST Act. Relying on its earlier decision in a materially identical fact situation, the HC held that the service provider acted as an independent service provider and not as an intermediary; consequently, the services qualified as export, and GST demand premised on &quot;intermediary&quot; characterization could not be sustained, leading to quashing of the impugned show cause notice to the extent of the specified audit objection. For the remaining audit objections, the petitioner was permitted to file replies with documents and the department was directed to proceed in accordance with law.</description>
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