Services rendered by a foreign group procurement hub to its Indian group entity, being core procurement services supplied on its own account and not ancillary facilitation, are not intermediary services under Sections 2(13) and 13(8)(b) of the IGST Act, and the tax paid thereon as import of services is not refundable though rejection cannot be sustained merely as an afterthought under Section 54 – Dow Chemical International Pvt. Ltd. Vs. Commissioner of State Tax, Mazgaon, Mumbai and Ors. – GSTAT Principal Bench
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