GST Refund Allowed as Services to foreign entities Qualify as Export, Not Intermediary Supply

KC Overseas Education Pvt. Ltd. Vs Union of India and Ors (Bombay High Court)

The Bombay High Court disposed of two writ petitions raising a common issue concerning the interpretation of “export of services” under Section 2(6) of the Integrated Goods and Services Tax Act, 2017 (IGST Act). The principal contention of the respondents was that sub-clause (iii) of Section 2(6), which requires the place of supply of service to be outside India, was not satisfied.

The Court held that Section 2(6) of the IGST Act must be read as a whole and not in a piecemeal manner. It emphasi

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