JUDGMENT

Vibhu Bakhru, J. (Oral)

CM APPL. 22428/2023 (for exemption)

1. Exemptions allowed, subject to all just exceptions.

2. The application stands disposed of.

W.P.(C) 5722/2023

3. The petitioner has filed the present appeal, inter alia, praying as under:

"a) Issue a writ of mandamus or any other appropriate writ, order or direction in the nature thereof, directing the Respondent to implement the Order-in-Appeal No. 120-123/2022-23 dated 28.07.2022, 114-115/2022-23 dated 28.07.2022 and 262/2021-22 dated 08.02.2022 passed by the Ld. Additional Commissioner, CGST Appeals-II, Delhi and expeditiously grant refund of Rs.2,62,01,727/- to the Petitioner along with applicable interest;

b) Pass such further orders and other reliefs as the nature and circumstances of the case may require."

4. The controversy between the parties is regarding the refund of Input Tax Credit availed on inputs/input services which the petitioner claims to have used for export of service.

5. Undisputedly, the export of services is treated as a zero-rated supply and the petitioner is entitled for refund of the Input Tax Credit under Section 16(3)(a) of the Integrated Goods and Service Tax Act, 2017 (hereafter `t