GST Appellate Tribunal, New Delhi ◆ 4 Jun 2026 Supply Valuation
Dow Chemical International (P.) Ltd. v. Commissioner of State Tax In favour of the revenue
Dow Chemical International Pvt. Ltd. appealed to the GST Appellate Tribunal, New Delhi (Appeal Nos. APL 2 to 7 (PB) of 2026, 4 June 2026), concerning fees paid to Dow Europe GmbH under a procurement support agreement for vendor identification and negotiation. The issue was intermediary versus import of services, place of supply under IGST Sections 2 and 13, and refund under Section 54 CGST read with Rule 89. The Tribunal found Dow Europe acted independently without authority to bind the Indian company; the supply was import of services with place of supply in India, IGST payable on reverse charge, and export-refund style claims rightly rejected. Outcome favoured revenue. Procurement support without binding agency is unlikely to qualify as intermediary services.
IGST S.13 IGST S.2 CGST S.54 CGST Rules R.89
