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    <title>APPELLATE ADVANCE RULING ON INTERMEDIARY / ZERO RATED SERVICES</title>
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    <description>Services rendered by the Indian back office provider constituted intermediary services because they arranged or facilitated supplies between the overseas client and its counterparties, satisfying the three part intermediary test; consequently the place of supply is the provider&#039;s location in India and the services are not eligible for zero rated treatment. The intermediary element was treated as the principal component of any composite supply after applying indicative criteria for naturally bundled services, and the provider&#039;s claim of supplying on its own account was rejected as the services related to the client&#039;s or its counterparty&#039;s goods.</description>
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      <description>Services rendered by the Indian back office provider constituted intermediary services because they arranged or facilitated supplies between the overseas client and its counterparties, satisfying the three part intermediary test; consequently the place of supply is the provider&#039;s location in India and the services are not eligible for zero rated treatment. The intermediary element was treated as the principal component of any composite supply after applying indicative criteria for naturally bundled services, and the provider&#039;s claim of supplying on its own account was rejected as the services related to the client&#039;s or its counterparty&#039;s goods.</description>
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