Conflict Between ‘Deemed Supply’ and ‘Export Benefits’: High Court Directs CBIC to Clarify Taxability of Services Provided to Foreign Entity Without Consideration (Network Agreement)

By | January 9, 2026

Conflict Between ‘Deemed Supply’ and ‘Export Benefits’: High Court Directs CBIC to Clarify Taxability of Services Provided to Foreign Entity Without Consideration (Network Agreement)

 

ISSUE

Whether a service provided to a foreign entity without consideration (under a mutual network agreement), which is treated as a “Supply” under Section 7(1)(a) of the CGST Act, can be denied the status of “Export of Service” (Zero Rated Supply) solely because convertible foreign exchange was not received, thereby creating a situation where the assessee is forced to pay tax on a transaction that yields no revenue.

FACTS

  • The Arrangement: The Assessee had a ‘Network Agreement’ with a German company. Under this, the Assessee delivered shipments for the German company’s clients in India, and the German company delivered shipments for the Assessee’s clients in Germany.

  • No Consideration: Crucially, there was no payment of consideration between the two companies for these reciprocal services.

  • Tax Payment: The Assessee paid tax on these services, treating them as a “Supply” under Section 7(1)(a) (Supply includes barter/exchange) read with Schedule I (activities to be treated as supply even without consideration – Note: Schedule I typically applies to related persons; here it seems the argument was Section 7(1)(a) itself covering non-monetary consideration in the form of counter-services).

  • The Conflict:

    • The Assessee’s Plea: Since the recipient (German company) is outside India, this should be an “Export of Service” (Zero Rated Supply).

    • The Barrier: Section 2(6) of the IGST Act defines “Export of Service” with a mandatory condition: receipt of payment in convertible foreign exchange. Since no money was exchanged, this condition was not met.

    • The Result: The Assessee was stuck in a legal trap—the law forced them to pay tax because it was a “Supply,” but denied them the “Zero Rated” benefit (Refund/Exemption) because they didn’t receive forex.

HELD

  • The Anomaly: The High Court acknowledged the incongruity. While non-receipt of forex technically disqualifies the transaction from being an “Export of Service” (depriving the assessee of zero-rating benefits), taxing a service that effectively earns no revenue (but is a reciprocal export arrangement) requires judicial scrutiny.

  • Harmonious Interpretation: The Court observed that Section 7 of the CGST Act (Supply), Section 16(1)(a) of the IGST Act (Zero Rated Supply), and Section 2(6) of the IGST Act (Definition of Export) need to be harmoniously interpreted.

  • Direction to CBIC: Recognizing that various High Courts are seized of this matter, the Court directed the CBIC (Central Board of Indirect Taxes and Customs) to examine this specific issue and place its stand before the High Court.

  • Status: The matter was listed for further hearing to resolve this legislative knot. [In Favour of Assessee (Notice Issued/Matter Listed)]


KEY TAKEAWAYS

  1. The “Barter” Trap: In international barter deals (Service A for Service B), GST law is tricky. It treats the service as a “Supply” (taxable) but often fails to recognize it as an “Export” because the definition of export is rigidly tied to “receipt of forex.”

  2. Valuation Challenge: Even if taxable, the valuation of such supplies is complex. It is usually based on the Open Market Value of similar services.

  3. CBIC Intervention: This order suggests that a policy clarification might be forthcoming to address situations where genuine exports happen via net-off or barter arrangements without physical forex remittance.

HIGH COURT OF DELHI
Dhl Express (India) (P.) Ltd.
v.
Union of India*
PRATHIBA M. SINGH and SHAIL JAIN, JJ.
W.P. (C) No. 17182 of 2025
DECEMBER  10, 2025
Rohan Shah, Sr. Adv. and Mohammed Anajwalla, Adv. for the Petitioner. Ms. Vaishali Gupta, Panel Counsel, Akash Panwar, Jr. Standing Counsel, Ms. Jasleen Kaur Anand, Adv. and Ajay Chowdhary, SPC for the Respondent.
ORDER
1. This hearing has been done through hybrid mode.
CM APPL. 70647/2025 (for exemption)
2. Allowed, subject to all just exceptions. The application is disposed of.
W.P.(C) 17182/2025
3. The present petition has been filed by the Petitioner- DHL Express (India) Private Limited under Article 226 and 227 of the Constitution of India, inter alia, seeking refund of the excess tax paid by the Petitioner.
4. The issue involved in the present petition is in respect of the interpretation of Section 7 of the Central Goods and Services Tax Act, 2017 (hereinafter, ‘CGST Act’)along with Section 16(1)(a) and 2(6) of the Integrated Goods and Services Tax Act, 2017 (hereinafter, ‘IGST Act’).
5. A brief background of the Petitioner’s case is that, the Petitioner-DHL Express (India) Private Limited (hereinafter, ‘DHL India’) has a ‘Network Agreement’ with DHL International GmbH (hereinafter, ‘DHL Germany’)under which, their respective clients are provided services, in India and in Germany, without payment of any consideration between the two companies.
6. Mr. Rohan Shah, ld. Sr. Counsel on behalf of the Petitioner submits that such services which are courier/shipment delivery services, are described as ‘Unbilled Shipments ‘ in the trade parlance.
7. DHL India discharged tax on such services as the same would constitute a service under Section 7(1)(a) read with Schedule 1 of the CGST Act, even though the same is without consideration.
8. However, it is submitted that since the entity which is receiving the service, i.e., DHL Germany is located abroad, the service which is provided would also constitute ‘Zero Rated Supply’ under Section 16(1) of the IGST Act.
9. One of the conditions for constituting ‘Zero Rated Supply’ is export of services under Section 2(6) of the IGST Act, however, it requires receipt of consideration in convertible foreign exchange, which is absent in the present case. Thus, the submission of ld. Counsel for the Petitioner is that if there is an incongruity in the provisions and the same deserves to be interpreted by this Court.
10. Additionally, ld. Sr. Counsel for the Petitioner also places reliance on the fact that three other High Courts, i.e., the High Court of Kerala, the High Court of Karnataka and the Madras High Court have already issued notice in these matters.
11. On the other hand, Ms. Vaishali Gupta, ld. Panel Counsel relies upon the order of the Division Bench of Bombay High Court in titled DHL Express India (P) Ltd. v. Union of India [Writ Petition No. 3977 of 2025, dated 19-11-2025] wherein, the Court had directed the Petitioner to first approach the concerned authorities by filing a refund application and the challenge by way of a writ petition was rejected by the Court.
12. Further, Mr. Akash Panwar, ld. JSC for the Central board of Indirect Taxes and Customs (hereinafter, ‘CBIC’) also submits that in terms of the Constitution Bench judgment in Mafatlal Industries Ltd. v. Union of India (1997) 5 SCC 536, the procedure for claiming a refund ought to be followed and no writ petition can be entertained in respect of refund applications directly, without an application for refund having been filed.
13. The Court has heard ld. Counsels for the parties. Insofar as the interpretation of Section 7 of CGST Act read with Section 16 of IGST Act is concerned, the matter deserves consideration inasmuch as the non-receipt of foreign exchange/consideration while on one hand does not exempt the Petitioner from paying taxes, it deprives the Petitioner of the benefits of export of services.
14. Prima facie, the Court is of the opinion that these aforesaid provisions would have to be harmoniously interpreted and a view would have to be taken by this Court.
15. Accordingly, issue notice only in respect of the interpretation of the aforesaid provisions and other relevant laws. Ms. Vaishali Gupta, ld. Panel Counsel accepts notice on behalf of Respondent No.3 and 4, Mr. Akash Panwar, ld. JSC accepts notice on behalf of Respondent No.2. Mr. Ajay Chowdhary, ld. SPC accepts notice on behalf of Respondent No.1.
16. Insofar as the prayer for refund itself is concerned, the same shall be considered only at a later stage, if the need so arises.
17. Considering the fact that various High Courts are considering the matter, let the CBIC look into this issue and may place its stand before this Court either by way of an affidavit or issue a clarification, if the need is so felt.
18. The stand of the Petitioner in the present petition may be treated as a representation.
19. Let this order be communicated to the CBIC by Mr Aakash Panwar, ld. JSC for the CBIC.
20. List on 26th February 2026.
Category: GST

About CA Satbir Singh

Chartered Accountant having 12+ years of Experience in Taxation , Finance and GST related matters and can be reached at Email : Taxheal@gmail.com