JUDGMENT :

SONIA GOKANI, J.

1. The petitioner is engaged in providing customer solution service and majority of the persons to whom it serves are located outside India. It is engaged in export of services as per the GST legislation. The petitioner opted for the option under Subsection 3(a) of Section 16 of the Integrated Goods and Service Tax Act, 2017 (‘the IGST Act’). The petitioner exports its services under bond or letter of undertaking without payment of integrated tax and claims refund of unutilised input tax credit.

2. Application for refund of unutilised input tax credit was preferred by the petitioner on 27.01.2021 aggregating to Rs.2,84,04,175/- for the period February, 2019 to March, 2020. This was assigned to the Deputy Commissioner, Sales Tax Circle- 2, Ahmedabad. The petitioner also substantiated its claim with necessary documents as sought by the authority, the physical copies of Foreign Inward Remittance Certificates (‘the FIRCs’ hereinafter) for the payments received during the period of refund application also have been tendered. This has been done in satisfaction of the authorities in terms of Rule 89(4)(d) of the Central Goods and Services Rules, 2017 (‘the CGST Ru