JUDGMENT

Vibhu Bakhru, J. The petitioner has filed the present petition, impugning an Order-in-Appeal dated 21.09.2021 (hereafter `impugned order'), inter alia, praying as under:

"a) Issue a writ of certiorari or any other appropriate writ or order or direction in the nature thereof, quashing the Order-in-Appeal No. 219-229/JC/CentralTax/App1-1/Delhi/2021 dated 21.09.2021 (enclosed at Annexure P1 of this Writ Petition) to the extent prejudicial to the Petitioner and consequently direct the Respondent No. 1 to grant refund amounting to Rs.25,04,738/- (as elaborated at Para 4.5 of the Writ Petition) along with interest; or"

2. The petitioner is, inter alia, engaged in the business of software development, content development, marketing and other IT and IT enabled services in the field of education technology. The petitioner claims that it exports education services to recipient in seventy countries without payment of GST. The said services are Zero Rated Supplies in terms of Section 16 of the Integrated Goods & Services Tax Act, 2017 (hereafter `IGST Act'). The petitioner is thus entitled to refund of Input Tax Credit (hereafter `ITC') relating to input services.

3. The petitioner is