https://www.taxtmi.com/caselaws?id=775478 Marketing and support activities were held not to constitute intermediary service where the agreement, read with the actual functions performed, did not show authority to conclude contracts for the overseas entity. Mere use of the labels "commercial agent" or "intermediary" was insufficient; an intermediary must arrange or facilitate a supply between at least three parties and not provide the main service on its own account. A cost-plus pricing model did not, by itself, establish intermediary status. On these facts, the service was treated as supplied on a principal-to-principal basis and qualified as export of service, so the service tax demand could not be sustained. en-us Thu, 24 Jul 2025 00:00:00 +0530 Sat, 26 Jul 2025 08:39:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=775478 Marketing and support activities were held not to constitute intermediary service where the agreement, read with the actual functions performed, did not show authority to conclude contracts for the overseas entity. Mere use of the labels "commercial agent" or "intermediary" was insufficient; an intermediary must arrange or facilitate a supply between at least three parties and not provide the main service on its own account. A cost-plus pricing model did not, by itself, establish intermediary status. On these facts, the service was treated as supplied on a principal-to-principal basis and qualified as export of service, so the service tax demand could not be sustained. Case-Laws Service Tax Thu, 24 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=775478