https://www.taxtmi.com/highlights?id=94671 HC examined whether Respondent's activities in recruiting students for foreign universities constituted "intermediary services" under Rule 2(f) of the POPOS Rules or export of services under Rule 6A of the Service Tax Rules, 1994. Noting that Respondent earned commission in foreign exchange for services rendered to foreign universities, HC applied the ratio of Ernst & Young Ltd, clarifying that only a person arranging or facilitating the supply is an intermediary and that place of supply for such services is governed by Section 13(2) IGST Act. Holding that the Adjudicating Authority's characterization was erroneous and that the services qualified as export, HC upheld the impugned order and dismissed the appeal. en-us Tue, 02 Dec 2025 08:35:09 +0530 Tue, 02 Dec 2025 08:35:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=94671 HC examined whether Respondent's activities in recruiting students for foreign universities constituted "intermediary services" under Rule 2(f) of the POPOS Rules or export of services under Rule 6A of the Service Tax Rules, 1994. Noting that Respondent earned commission in foreign exchange for services rendered to foreign universities, HC applied the ratio of Ernst & Young Ltd, clarifying that only a person arranging or facilitating the supply is an intermediary and that place of supply for such services is governed by Section 13(2) IGST Act. Holding that the Adjudicating Authority's characterization was erroneous and that the services qualified as export, HC upheld the impugned order and dismissed the appeal. Highlights Service Tax Tue, 02 Dec 2025 08:35:09 +0530 https://www.taxtmi.com/highlights?id=94671