https://www.taxtmi.com/caselaws?id=784354 The dominant issue was whether the petitioner's supply of electricity, routed through an intermediary to a foreign buyer, qualified as "export of goods" and a zero-rated supply under ss. 2(5) and 16 of the IGST Act read with Art. 286. The HC held that while export principles must be derived from Art. 286 and the IGST Act (not s. 5(2) of the CST Act), the contractual structure showed no privity between the petitioner and the foreign buyer; title passed to the intermediary at the Indian delivery point, and the petitioner's supply was only "for export" and not an export supply. Consequently, the supply to the intermediary was treated as domestic, the writ petitions were dismissed, and the petitioner was permitted to refile refund claims applying the domestic-supply treatment in the Rule 89 formula. en-us Wed, 31 Dec 2025 00:00:00 +0530 Fri, 02 Jan 2026 07:51:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784354 The dominant issue was whether the petitioner's supply of electricity, routed through an intermediary to a foreign buyer, qualified as "export of goods" and a zero-rated supply under ss. 2(5) and 16 of the IGST Act read with Art. 286. The HC held that while export principles must be derived from Art. 286 and the IGST Act (not s. 5(2) of the CST Act), the contractual structure showed no privity between the petitioner and the foreign buyer; title passed to the intermediary at the Indian delivery point, and the petitioner's supply was only "for export" and not an export supply. Consequently, the supply to the intermediary was treated as domestic, the writ petitions were dismissed, and the petitioner was permitted to refile refund claims applying the domestic-supply treatment in the Rule 89 formula. Case-Laws GST Wed, 31 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784354