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    <description>Refund of unutilized input tax credit on zero-rated export services cannot be denied by classifying a supplier as an intermediary for an isolated period where identical services were treated as exports and refunds were granted in preceding and succeeding periods. In the absence of material showing that services during the disputed period differed or warranted intermediary classification, the inconsistent treatment is arbitrary and discriminatory. The supplier is entitled to the refund with applicable interest.</description>
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