Where applicant and foreign colleges are nowhere related to each other, thus, applicant cannot be treated as establishment of a distinct person in accordance with Explanation 1 to Section 8 of IGST Act; activity of applicant for foreign college and university should qualify as ‘export of service’ in terms of Section 2(6) of IGST Act provided payments are received in convertible foreign exchange – Center for International Admission and Visas (CIAV), In re – [2024] 162 taxmann.com 681 (AAR- TELANGANA)