IN THE HIGH COURT OF JUDICATURE AT BOMBAY ORDINARY ORIGINAL CIVIL JURISDICTION WRIT PETITION NO. 5144 OF 2022 WITH WRIT PETITION NO2774 OF 2024 IDP Education India Pvt Ltd .. Petitioner Versus Union of India & Ors .. Respondents Mr. Prasad Paranjape, with Mr. Bhavya Varma i/b Lumiere Law Partners, Advocates for the Petitioner in WP.5144/22 and WP.2774/24.

ANJALI D byig Ait Nal JAy L s Iigned TUSHART AU SWSH AA LR E ASWALEDate: 2025.05.07

14:54:00 +0530 Mr. Vijay H. Kantharia, with Mamta Omle, Advocates for the Respondents in WP.5144/22 and WP.2774/24.

CORAM: B. P. COLABAWALLA &

FIRDOSH P. POONIWALLA, JJ.

DATE: MAY 5, 2025 P. C.

1. Heard learned counsel for the parties.

2. Rule. Respondents waive service. Rule is made returnable forthwith and heard finally by consent of parties.

3. These two Petitions raise a common question as to whether the Petitioners qualify as “Intermediary” under Section 13 (8) read with Section 2 (13) of the Integrated Goods and Services Tax Act, 2017 (“IGST Act”) and therefore are being taken up together for disposal.

4. Writ Petition No. 5144/2022 is for the period March 2019 to April 2020, where IGST of Rs.5,87,01,143 paid by the Petitioner on services supplied by