Section 54 of the CGST Act, 2017 --- Refund —- The petitioner sought direction to the Respondent to implement the Order-in-Appeal dated 28.07.2022, dated 28.07.2022 and dated 08.02.2022 and to grant refund of Rs. 2,62,01,727/- along with applicable interest. The Petitioner sought refund of ITC availed on inputs / input services which were used for export of service. The petitioners’ claims for refund were rejected, on the ground that the services provided by the petitioner were intermediary services and did not qualify for export of services. The petitioner filed an appeal against the orders and the authority allowed the said appeals. The petitioner again filed Form GST RFD-01 for grant of refund along with interest. The respondent did not process the petitioner’s claim for refund and issued the Deficiency Memos and Show Cause Notice. The court did not appreciate the insistence on the part of the Revenue for the appellant to file fresh applications for the refund. The respondent counsel stated that fresh applications for refund or Show Cause Notices would not be necessary.

Held that:- The Hon’ble Court allowed the petition and tretaed the applications and the deficiency memos as non est and directed that the petitioner would also be entitled to interest in accordance with law.