Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
CESTAT ruled against Revenue's contention that services constituted intermediary services u/r 9 of Place of Provision of Service Rules, 2012. The Tribunal emphasized that intermediary services require a tripartite arrangement involving a supplier, recipient, and facilitator. In this case, only a bipartite agreement existed between Respondent and overseas clients for identifying prospective buyers. The services were provided directly on Respondent's own account, not facilitating supply between parties. Following precedents from IDEX India and Cube Highways cases, which established that advisory services rendered independently do not qualify as intermediary services, CESTAT dismissed Revenue's appeal, confirming the services qualified as export of services.
CESTAT ruled against Revenue's contention that services constituted intermediary services u/r 9 of Place of Provision of Service Rules, 2012. The Tribunal emphasized that intermediary services require a tripartite arrangement involving a supplier, recipient, and facilitator. In this case, only a bipartite agreement existed between Respondent and overseas clients for identifying prospective buyers. The services were provided directly on Respondent's own account, not facilitating supply between parties. Following precedents from IDEX India and Cube Highways cases, which established that advisory services rendered independently do not qualify as intermediary services, CESTAT dismissed Revenue's appeal, confirming the services qualified as export of services.
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