ORDER :

Sujoy Paul, J.

This Writ Petition filed under Article 226 of the Constitution impugns the Order-in-Appeal (OIA) No.AAAR/04/2022 dated 16.07.2022, whereby the view of the Advance Ruling Authority dated 05.08.2021 (Annexure P-18) was affirmed.

Petitioner’s case:-

2. The Government of India (GoI) entered into Memorandum of Understanding (MoU) with Government of Maldives for constructing a Police Academy funded by the GoI. In turn, the GoI appointed respondent No.2 i.e., National Buildings Construction Corporation Ltd., (NBCCL) to execute the construction of Police Academy by itself or through a contractor. NBCCL awarded contract to the petitioner.

3. In order to complete the work at Republic of Maldives (Maldives), the NBCCL set up an office and in turn the petitioner also set up their office at Addu city, Maldives. The Authorized Dealer Bank {Oriental Bank of Commerce (OBC)}, which is acting on behalf of Reserve Bank of India approved the establishment of branch office of petitioner in Maldives.

4. The stand of the petitioner is that it exported various goods to its Maldives office. The turnover of such goods was declared under the GST as ‘zero rate supplies’. The petitioner treate