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    <description>Support services provided to an overseas client on a principal-to-principal basis, including customer identification, product briefing, pricing information and incidental evaluation support, were treated as business support services rather than intermediary services because the provider did not arrange or facilitate a supply between two other persons and its remuneration was cost plus markup, not sales-linked. On that basis, the place of provision was not shifted to India as an intermediary supply. The services were therefore regarded as export of services, and the refund claim could not be denied on the reasoning adopted in the impugned order; the refund rejection was set aside with consequential relief.</description>
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