Place of supply of advertising services: principal-to-principal deals treat recipient abroad, enabling export classification under default rule. Where an Indian advertising company contracts comprehensively with a foreign client and separately with media owners, it supplies services on its own account on a principal-to-principal basis and is not an intermediary; the recipient is the foreign client and the place of supply defaults to the recipient's location outside India, qualifying as export of services subject to export conditions. Conversely, where the agency merely facilitates a direct contract between foreign client and media owner and invoices only for facilitation, it is an intermediary and place of supply rules for intermediaries apply.
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Place of supply of advertising services: principal-to-principal deals treat recipient abroad, enabling export classification under default rule.
Where an Indian advertising company contracts comprehensively with a foreign client and separately with media owners, it supplies services on its own account on a principal-to-principal basis and is not an intermediary; the recipient is the foreign client and the place of supply defaults to the recipient's location outside India, qualifying as export of services subject to export conditions. Conversely, where the agency merely facilitates a direct contract between foreign client and media owner and invoices only for facilitation, it is an intermediary and place of supply rules for intermediaries apply.
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