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AAR held that the applicant's activities constitute intermediary services within the meaning of Section 2(13) of the IGST Act, 2017, rather than independent consultancy (marketing, recruitment or referral) or provision of education. The applicant merely facilitates the supply of education by foreign universities to Indian students, earning commission contingent on successful admissions, and lacks strategic autonomy or expert-driven consultancy functions. Consequently the applicant supplies services as an intermediary, with place of supply located in India under Section 13(8)(b); therefore the services do not meet the statutory criteria for export of services under Section 2(6) and are taxable under the IGST regime.
AAR held that the applicant's activities constitute intermediary services within the meaning of Section 2(13) of the IGST Act, 2017, rather than independent consultancy (marketing, recruitment or referral) or provision of education. The applicant merely facilitates the supply of education by foreign universities to Indian students, earning commission contingent on successful admissions, and lacks strategic autonomy or expert-driven consultancy functions. Consequently the applicant supplies services as an intermediary, with place of supply located in India under Section 13(8)(b); therefore the services do not meet the statutory criteria for export of services under Section 2(6) and are taxable under the IGST regime.
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