Purposive interpretation of residential house exemption: unregistered purchase agreement alone does not defeat relief, but investment must be verified...
CESTAT held that services provided by appellant to overseas educational institutions constituted export of services, not intermediary services. The appellant rendered services directly to foreign universities/colleges and received commission upon successful student admissions. These services satisfied all conditions under Rule 6A for classification as export services, including direct provision to foreign recipients with payment in foreign exchange. Following precedent established in Sunrise Immigration Consultants Private Limited, the Tribunal determined that referral services for foreign universities qualify as export services when the provider acts on its own account rather than as an intermediary. Appeal allowed.
CESTAT held that services provided by appellant to overseas educational institutions constituted export of services, not intermediary services. The appellant rendered services directly to foreign universities/colleges and received commission upon successful student admissions. These services satisfied all conditions under Rule 6A for classification as export services, including direct provision to foreign recipients with payment in foreign exchange. Following precedent established in Sunrise Immigration Consultants Private Limited, the Tribunal determined that referral services for foreign universities qualify as export services when the provider acts on its own account rather than as an intermediary. Appeal allowed.
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