Overseas university admission-facilitation services supplied to...

Overseas university admission-facilitation services supplied to foreign universities do not constitute intermediary services merely because the provider is described as an agent and receives commission. Intermediary status requires three parties and two distinct supplies: a main supply and a separate ancillary facilitation supply. Where the provider supplies the principal service on its own account, without a tripartite arrangement or multiple supplies, the service qualifies as export of services. For the small service provider exemption, exported-service value is excluded from the aggregate-value threshold; consequently, commission from domestic educational institutions within the prescribed limit is not subject to service tax.