VIBHU BAKHRU, AMIT MAHAJAN
Ernst And Young Limited – Appellant
Versus
Additional Commissioner, CGST Appeals-ii, Delhi – Respondent
JUDGMENT
Vibhu Bakhru, J. The petitioner is an Indian Branch Office of M/s Ernst & Young Limited and has filed the present petition impugning an order-in-appeal dated 15.03.2022 (Order-in-Appeal No.311-313/2021-22) (hereafter `the impugned order') passed by the Additional Commissioner of CGST Appeal-II (hereafter `the Appellate Authority'), whereby respective appeals preferred by the petitioner against orders-in-original dated 25.01.2020, 09.12.2020 and 21.05.2021 (hereafter `the impugned orders-in-original') passed by the Assistant Commissioner, CGST, Division Vasant Kunj (hereafter `the Adjudicating Authority') were rejected.
2. The petitioner had appealed against the impugned orders-in-original passed by the Adjudicating Authority being aggrieved by the rejection of its refund applications for input tax credit (hereafter `ITC') in respect of export of services for the period from December 2017 to March 2020. The Adjudicating Authority had denied the said applications for refund of ITC on the premise that the petitioner is an `intermediary' and thus, the place of services is located in India, where the petitioner's place of business is located and not where recipient of services
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