JUDGMENT

Vibhu Bakhru, J. (Oral)

1. The petitioner has filed the present petition impugning an Order- in-Appeal (Appeal No.433/JC/Central Tax/App-I/Delhi/2019) dated 28.12.2021 ( hereafter `the impugned order'), passed by the Appellate Authority (Joint Commissioner, CGST Appeals-I, Delhi), whereby the petitioner's appeal against an order dated 10.01.2020, passed by the Adjudicating Authority was rejected.

2. The petitioner claims that it is engaged in the business of exporting services to Netgear Pte. Ltd. without payment of Integrated Goods and Services Tax (IGST). The petitioner claims that since the supplies made are zero rated supplies, it is entitled to the refund of Input Tax Credit (ITC). In this context, on 04.08.2020, the petitioner filed an application (ARN AA070820005153S), seeking refund of an amount of

3. The Adjudicating Authority (respondent no.2) issued a show cause notice dated 19.08.2020, inter alia, proposing to reject the petitioner's claim for refund on the ground that the petitioner was merely facilitating and arranging services and thus, qualified as an intermediary within the meaning of Section 2(13) of the Integrated Goods and Services Tax Act, 2017 (her