The refund was rejected on the ground that the petitioner qualified as an ‘intermediary’ under Section 2(13) of the IGST Act, attracting Section 13(8)(b) read with Section 2(6). The petitioner primarily contended that the department had previously and subsequently granted refunds for the same services, treating it as an exporter rather than an intermediary. The Court set aside the appellate order dated 16.12.2022 and directed release of the refund amount with applicable interest within four weeks from uploading of the order. The rejection of the petitioner’s claim for refund, would therefore be illegal and arbitrary, and cannot sustain. The impugned order dated 16.12.2022 (Annexure P-1) is accordingly set aside.