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    <title>2026 (1) TMI 84 - KARNATAKA HIGH COURT</title>
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    <description>Whether exported services were &quot;intermediary services&quot; under the IGST Act so as to deny refund of accumulated unutilized ITC. On construing the service agreement with the foreign parent and considering prior refund sanctions under pre- and post-GST regimes and binding HC precedents, the HC held the petitioner acted on a principal-to-principal basis and did not arrange or facilitate supplies for another as an intermediary. Consequently, the supplies remained zero-rated under s.16 of the IGST Act, and denial of refund on the intermediary ground was unsustainable; the impugned order-in-original and computation sheet were quashed to that extent, and the petition was allowed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=784328</link>
      <description>Whether exported services were &quot;intermediary services&quot; under the IGST Act so as to deny refund of accumulated unutilized ITC. On construing the service agreement with the foreign parent and considering prior refund sanctions under pre- and post-GST regimes and binding HC precedents, the HC held the petitioner acted on a principal-to-principal basis and did not arrange or facilitate supplies for another as an intermediary. Consequently, the supplies remained zero-rated under s.16 of the IGST Act, and denial of refund on the intermediary ground was unsustainable; the impugned order-in-original and computation sheet were quashed to that extent, and the petition was allowed.</description>
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