JUDGMENT :

The prayers in the afore-captioned Writ Petition (Civil) are as follows:

“(i) Issue a writ of certiorari or any other appropriate writ, order or direction as this Hon'ble Court deems fit and proper in the circumstances of the case, calling for the records leading to the issue of Exhibit P-2 Order and after scrutinizing the same, to strike down and quash the same and to hold that in the given set of facts available before the AAR, the transaction in question would not attract GST since the subject transaction would quality for “Export of Services” in terms of Section 2(6) of IGST Act, 2017.

(ii) issue such other appropriate writ, direction or order as deemed fit by this Honourable court, considering the facts and circumstances of the case, in the interest of justice.”

2. Heard Sri.Joseph Prabakar, learned counsel appearing for the petitioner, Smt.Preetha S.Nair, learned Central Government Counsel (CGC) appearing for R-1 & R-3 and Dr.Thushara James, learned Government Pleader appearing for R-2.

3. The case projected in this Writ Petition (Civil) is as follows:-The petitioner, M/s.Sutherland Mortgage Services Inc., now functioning in the office premises in the Cochin Special Ec