IDP EDUCATION INDIA PVT. LTD. v. THE UNION OF INDIA & ORS. – RAJASTHAN HIGH COURT
High Court, Rajasthan
K.R. Shriram, Chief Justice & Maneesh Sharma, Justice
IDP EDUCATION INDIA PVT. LTD.
v.
THE UNION OF INDIA & ORS.
D.B. CIVIL WRIT PETITION No. 9933/2024 WITH D.B. CIVL WRIT PETITION No. 9967/2024 dated 04.09.2025
Law : GST
Act Name : Integrated Goods & Service Tax Act, 2017
Relevant Section : Section 2 & 16
Decision : Matter remanded back
Refund – Classification of services – Whether petitioner services qualify as “intermediary” under Section 2(13) IGST Act or as “export of services” – Petitioner, subsidiary of IDP Australia provided student placement and counselling services to IDP Australia under bipartite agreement, consideration received as share of application processing fee – Authorities held petitioner to be “intermediary” and denied export status/refund – Court noted for “intermediary” three parties required – Services rendered only to IDP Australia on principal-to-principal basis without any contract with foreign universities/students and without role in admission decisions – Services amount to export of services and refund of IGST payable – Reliance placed on CESTAT order CBIC Circular 20.09.2021 stating no change in scope of intermediary pre- and post-GST and decision in IDP Education India Pvt. Ltd. v. Union of India (2025 Taxo.online 3054) – Held: Petitions allowed – Matter remanded to Adjudicating Authority to process refund with applicable interest within 4 weeks.
Represented By:
Counsel for the Petitioner: Prasad Pranjape with Nitin Jain
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