Electricity supplied to intermediary for onward export: treated as domestic sale, so no zero-rated IGST refund

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....Whether supply of electricity by the petitioner to an intermediary for onward supply outside India qualified as "export of goods" (zero-rated) for IGST refund was decided by construing Article 286(1)(b) and Sections 2(5) and 16 of the IGST Act. Since the petitioner had no privity of contract with the foreign buyer and title passed at the domestic delivery point from the petitioner to the intermediary, the petitioner's supply was only "for export" and not an export supply; consequently, it was a domestic supply and not eligible for zero-rated refund on that leg. The petitions were dismissed, with liberty to refile refund claims applying Rule 89 treating the intermediary supply as domestic. - HC....