2026 (7) TMI 1918

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....oner : Ms. Krati Singh, Advocate, Ms. Samiksha Uniyal, Advocate and Ms. Khushi Satviki, Advocate For the Respondent-CGST : Mr. Sourabh Goel, Sr. Panel Counsel ORDER ROHIT KAPOOR J. (Oral) 1. The petitioner, who claims to be engaged in the business of export of information technology and other business support services, on the basis of an agreement with its overseas parent company, situ....

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....of the IGST Act, and hence does not qualify for the refund keeping in view the provisions of Section 13 (8) (b) Section 2 (6) of the said Act. 3. Although various submissions have been advanced by the learned counsel for the petitioner, however, she has primarily assailed the order impugned on the short ground that the same violates the principle of consistency and is arbitrary, inasmuch as, th....

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....ogies India Pvt. Ltd. Vs. Commissioner of Central Goods and Service Tax and others, wherein, in identical circumstances, it was held that where the same entity is treated differently as an exporter and intermediary, and when no reasons are forthcoming to distinguish the rendering of services, then such an approach would be held to be discriminatory. 4. Learned counsel appearing on behalf of the....