The GSTAT, Mumbai (Division Bench) in M/s. Dow Chemical International Private Ltd. v. Commissioner of State Tax, Mazgaon, Mumbai [Final Order in Appeal Nos. APL/2/PB/2026 to APL/7/PB/2026 dated June 04, 2026] dismissed the appeals filed by the assessee and held that procurement support services provided by Dow Europe GmbH (Switzerland) — functioning as the centralized procurement hub of the Dow Group — to its Indian affiliate do not qualify as “intermediary services” within the meaning of Section 2(13) of the Integrated Goods and Services Tax Act, 2017 (“the IGST Act”), but rather constitute an “import of services” with the place of supply being in India, and consequently, the refund of IGST paid under the Reverse Charge Mechanism (“RCM”) for the period January 2022 to June 2022 cannot be granted.
