Export of Services: Rajasthan HC Rules for Principal-to-Principal Contracts

Quick Summary

The Rajasthan High Court has ruled that services provided under a principal-to-principal agreement, where the provider acts on their own account without facilitating for a third party, are considered an export of services. This decision clarifies that such arrangements do not fall under the definition of 'intermediary services' as per the IGST Act. Consequently, the petitioner is entitled to an IGST refund.

Court :
Rajasthan High Court

Brief :
The Hon'ble Rajasthan High Court in the case of IDP Education India Pvt. Ltd. v. Union of India & Ors. [Civil Writ Petition No. 9933/2024, order dated September 04, 2025] held that services rendered by the Petitioner to IDP Australia under a bi-partite agreement, without any contractual relationship with students, do not qualify as intermediary services under Section 2(13) of the IGST Act. Consequently, these services qualify as "export of services" and the Petitioner is entitled to IGST refund.

Citation :
Civil Writ Petition No. 9933/2024, order dated September 04, 2025

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