In Export of Service, in which there is section 2(6)(V), which says that the service provider and the recipient of service are not merely establishement of a distinct person but distinct legal entities in accordance with Explanation 1 in section 8. Does it refers only to deemed distinct person Means if they are related parties and comes under the definition of related parties but still they shall qualify into export of services Because i feel they are only talking about deemed distinct person and even if they are related parties they shall qualify into export of service Sir what's your opinion on that?

Reply—As per Section 2(6) of IGST Act, following is one of the component of export of service—

the supplier of service and the recipient of service are not merely establishments of a distinct person in accordance with Explanation 1 in section 8.

Explanation 1.–– For the purposes of this Act, where a person has,––

(i) an establishment in India and any other establishment outside India;
(ii) an establishment in a State or Union territory and any other establishment outside that State or Union territory; or
(iii) an establishment in a State or Union territory and any other establishment registered within that State or Union territory, then such establishments shall be treated as establishments of distinct persons.

As per above provision, if transaction is between related parties it will not be considered as export of service.