Can GST Authorities deny refund by inconsistently classifying the same services as ‘Intermediary’?

This judgment reinforces the principle of consistency in GST administration. Once the department has accepted a particular nature of supply and granted benefits for identical transactions, it cannot adopt a contrary stand for an intervening period without demonstrating any material change in facts. The ruling provides significant relief to exporters facing arbitrary classification as intermediaries and emphasizes that tax authorities must maintain consistency in the treatment of similar transactions.