COMMISSIONER OF DELHI GOODS AND SERVICE TAX DGST DELHI v. GLOBAL OPPORTUNITIES PRIVATE LIMITED THROUGH ITS AUTHORIZED REPRESENTATIVE
High Court, Delhi
Prathiba M. Singh, Justice & Shail Jain, Justice
COMMISSIONER OF DELHI GOODS AND SERVICE TAX DGST DELHI
v.
GLOBAL OPPORTUNITIES PRIVATE LIMITED THROUGH ITS AUTHORIZED REPRESENTATIVE
W.P.(C) 10189/2025 & CM APPL. 42299/2025 dated 25.09.2025
Law : GST
Act Name : Integrated Goods & Service Tax Act, 2017
Relevant Section : Section 5 & 13
Decision : In favour of assessee
Refund – Export of services – Whether respondent educational consultancy services to Indian students for foreign universities qualify as export of services under Section 2(6) of IGST Act? – Whether respondent is ‘intermediary’ under Section 2(13) of IGST Act? – Department contended respondent acted as intermediary and ineligible for export benefits, while Appellate Authority found relationship was principal-to-principal qualifying as export of services -Various judicial precedents and relevant Supreme Court rulings affirmed supplier providing services directly to foreign recipient not intermediary – GST Council’s 56th meeting clarified place of supply for intermediary services is recipient location, supporting export benefit claims – Held: Petition disposed – Court upheld Appellate authority orders directing department to process refund with statutory interest.
Represented By:
Counsel for the Petitioner: Sameer Vashisht, SSC with Urvi Mohan, Naman Jain with Deepak Kumar, Advs.
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