Consistency in export-service classification supports input tax credit refunds where identical services lack distinguishing features.

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....Consistent treatment of identical export services is central to refund eligibility for unutilised input tax credit on zero-rated supplies. The note states that services granted refunds in periods before and after the disputed period should not be classified as intermediary services for the intervening period without material distinguishing their nature. Such differential classification is described as arbitrary, discriminatory and contrary to the principle of consistency. It records that rejection of the refund claim was set aside and release of the refund with applicable interest was directed.....