- 1 - HC-KAR CNR: KAHC010211692024 NC: 2026:KHC:36827 WP No. 11136 of 2024 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 17TH DAY OF JULY, 2026 BEFORE THE HON'BLE MR. JUSTICE B M SHYAM PRASAD WRIT PETITION NO. 11136 OF 2024 (T-RES) BETWEEN: M/S IBS SOFTWARE PRIVATE LIMITED HAVING OFFICE CRESCENT 1, PRESTIGE SHANTINIKETAN, LEVEL 11, WHITEFIELD MAIN ROAD, WHITEFIELD, BENGALURU (BANGALORE) URBAN, KARNATAKA -560048 COMPANY REGISTERED UNDER COMPANIES ACT OF 1956 REPRESENTED BY THEIR AUTHORISED SIGNATORY, ASHISH NANDA, THE CHIEF OPERATING OFFICER, AGED ABOUT 50 YEARS, R/AT F-30-31, BLOCK-F, LAJPAT NAGAR-II, DELHI-110024. …PETITIONER (BY SRI. PRASHANTH S SHIVADASS.,ADVOCATE) AND: 1. ADDITIONAL COMMISSIONER OF GST APPEALS -I TRAFFIC TRANSIT Digitally signed by VANAMALA N Location: HIGH COURT OF KARNATAKA - 2 - HC-KAR CNR: KAHC010211692024 NC: 2026:KHC:36827 WP No. 11136 of 2024 MANAGEMENT CENTRE, BMTC BUILDING, 4TH FLOOR, ABOVE BMTC BUS STAND, DOMLUR, OLD AIRPORT ROAD, BANGALORE-560071. 2. DEPUTY COMMISSIONER GST COMMISSIONERATE BENGALURU EAST, 2ND FLOOR, TRAFFIC AND TRANSIT MANAGEMENT CENTRE, BMTC BUS STAND, OLD AIRPORT ROAD, DOMMALURU, BENGALURU-560071. …RESPONDENTS (BY SRI. ARAVIND V CHAVAN.,ADVOCATE) THIS WP IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO A) QUASH AND SETTING ASIDE THE IMPUGNED ORDER IN APPEAL VIDE NO. 27/2024/ADC-AI/GST DATED 17/01/2024 PASSED BY R1 ENCLOSED AT ANNEXURE- A; B) HOLDING THAT THE PETITIONER IS ELIGIBLE FOR REFUND OF RS. 2,98,50,776/- CLAIMED UNDER APPLICATION ENCLOSED AT ANNEXURE-R; C) HOLDING THAT THE AMOUNTS RECEIVED IN BANK ACCOUNTS OF THE COMPANY PERTAINING TO THE EXPORT OF SERVICES UNDERTAKEN BY THE PETITIONER IS TO BE CONSTRUCTED AS RECEIPT OF - 3 - HC-KAR CNR: KAHC010211692024 NC: 2026:KHC:36827 WP No. 11136 of 2024 CONSIDERATION IN CONVERTIBLE FOREIGN CURRENCY BY THE PETITIONER; D) HOLDING THAT THE TWO E-BRCS RECEIVED IN THE RELEVANT PERIOD ARE TO BE CONSIDERED FOR DETERMINING ZERO-RATED SUPPLY, EVEN WHEN THE CONSIDERATION FOR THE SAME WAS RECEIVED IN THE EARLIER PERIOD; E) HOLDING THAT PETITIONER IS ELIGIBLE FOR INTEREST UNDER SECTION 56 OF THE CENTRAL GOODS AND SERVICES TAX ACT, 2017. THIS PETITION, COMING ON FOR ORDERS, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE B M SHYAM PRASAD ORAL ORDER The petitioner has called in question the Order- in-Appeal under Section 107 of the Central Goods and Services Tax Act, 2017/Karnataka Goods and Services Tax Act, 2017 [for short, ‘the Act’]. Presently, an application [IA No.1/2026] is filed for leave to withdraw the present petition and avail appellate remedy under Section 112 of the Act with a newly constituted appeal Tribunal. - 4 - HC-KAR CNR: KAHC010211692024 NC: 2026:KHC:36827 WP No. 11136 of 2024 The petition stands disposed of with liberty as aforesaid. The application in IA No.1/2026 also stands disposed of. Sd/- (B M SHYAM PRASAD) JUDGE SA Ct:sr