9911796707
TMI Blog2023 (7) TMI 1228X X X X Extracts X X X X X X X X Extracts X X X X ..... THE PETITIONER : SRI. P B HARISH , ADVOCATE FOR THE RESPONDENTS : SRI. ARAVIND V. CHAVAN , ADVOCATE ORDER The petitioner has sought for an appropriate order to declare that the impugned order dated 23.03.2020 at Annexure-'A' affirming the order passed by respondent No.2 at Annexure-'B' dated 17.07.2019 is illegal. The petitioner has also sought for quashing of the order at ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ation of direct and indirect costs with mark up of 20% that was permitted, which according to the petitioner would be the consideration for the services rendered to the Group Companies. The petitioner asserts that the Company is undisputedly involved in zero rated supply of services in terms of Section 16(1) of the Integrated Goods and Services Tax Act, 2017 ('IGST Act' for brevity). 5. T ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r the latter course. The petitioner has stated that the applications for refund of tax for the period of December 2017 under Section 16 of IGST Act and Section 54 of Central Goods and Services Tax Act, 2017 ('CGST Act' for brevity), was partially rejected and refund of Rs.66,68,794/- was not accepted on the ground that they were mere adjustment bills to make up the shortfall of petitioner ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the matter may require clarity on the aspect as to whether services were actually rendered during December 2017 and it is only on such factual finding that the matter could be resolved. 11. It is submitted that such factual aspect is a matter that cannot be argued at this stage and the adjudication ought to be directed to be redone for recording of finding on that specific aspect. 12. After hear ..... X X X X Extracts X X X X X X X X Extracts X X X X
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