Principal-to-principal overseas services qualify as exports when statutory conditions are met, supporting input tax credit refunds.
Case-Laws
GST
Intermediaries arrange or facilitate supplies for others, while services supplied on a principal-to-principal basis on the supplier's own account are not intermediary services. Such services to overseas group entities qualify as exports where the recipient and place of supply are outside India, payment is received in convertible foreign exchange, and the Indian supplier and foreign recipient are separately incorporated. Qualifying exports support refunds of unutilised input tax credit with statutory interest. Principal Bench jurisdiction applies to refund appeals involving place of supply, including where intermediary status determines it. Refund rejection grounds must be specified in the show-cause notice and appellate findings reasoned; inadequately communicated grounds violate natural justice.
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