https://www.taxtmi.com/caselaws?id=783924 Consultancy/support services provided under representative agreements to overseas recipients were examined to determine whether they constituted intermediary services taxable in India or export of service eligible for refund. The Tribunal held that the service provider acted as an independent contractor with no authority to bind the foreign recipient, negotiate pricing, sign contracts, or render services to Indian end customers on the recipient's behalf; hence it was not an intermediary arrangement. The Tribunal further held that Rule 4(a) of the Place of Provision of Services Rules, 2012 was inapplicable as performance did not involve goods being made physically available, and the services fell under Rule 3 as export; the beneficiary's location in India was irrelevant. Refund rejection was set aside and the appeal was allowed. en-us Mon, 08 Dec 2025 00:00:00 +0530 Fri, 26 Dec 2025 07:18:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783924 Consultancy/support services provided under representative agreements to overseas recipients were examined to determine whether they constituted intermediary services taxable in India or export of service eligible for refund. The Tribunal held that the service provider acted as an independent contractor with no authority to bind the foreign recipient, negotiate pricing, sign contracts, or render services to Indian end customers on the recipient's behalf; hence it was not an intermediary arrangement. The Tribunal further held that Rule 4(a) of the Place of Provision of Services Rules, 2012 was inapplicable as performance did not involve goods being made physically available, and the services fell under Rule 3 as export; the beneficiary's location in India was irrelevant. Refund rejection was set aside and the appeal was allowed. Case-Laws Service Tax Mon, 08 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783924