https://www.taxtmi.com/caselaws?id=440446 Services rendered on a principal-to-principal basis, involving promotional, marketing and technical support, were not intermediary services because the assessee did not arrange or facilitate a supply between the overseas recipient and its customers. The arrangement was confined to the assessee and the foreign recipient, with consideration on a cost-plus basis unrelated to downstream sales, so the intermediary classification failed. The court also held that services falling within section 65(105)(zzb) were not outside the export framework merely by reason of that classification; refund of unutilised CENVAT credit could not be denied unless the export rules specifically excluded the service. The Revenue's challenge failed and the refund entitlement was sustained. en-us Wed, 12 Jul 2023 00:00:00 +0530 Tue, 23 Dec 2025 14:28:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=440446 Services rendered on a principal-to-principal basis, involving promotional, marketing and technical support, were not intermediary services because the assessee did not arrange or facilitate a supply between the overseas recipient and its customers. The arrangement was confined to the assessee and the foreign recipient, with consideration on a cost-plus basis unrelated to downstream sales, so the intermediary classification failed. The court also held that services falling within section 65(105)(zzb) were not outside the export framework merely by reason of that classification; refund of unutilised CENVAT credit could not be denied unless the export rules specifically excluded the service. The Revenue's challenge failed and the refund entitlement was sustained. Case-Laws Service Tax Wed, 12 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=440446