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    <title>2026 (1) TMI 145 - KARNATAKA HIGH COURT</title>
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    <description>The dominant issue was whether marketing support and technical support services supplied to a foreign recipient under a master service agreement constituted &quot;intermediary services&quot; under s.2(13) of the IGST Act, thereby disentitling refund of accumulated input tax credit. On construing the agreement and contemporaneous records, the HC held the supplier was providing services on its own account and not arranging or facilitating supply between third parties; the supplies therefore qualified as export of services. Consequently, the adjudication and appellate orders treating the supplies as intermediary and raising IGST demand were quashed, and the tax authorities were directed to grant/sanction the claimed refund.</description>
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      <description>The dominant issue was whether marketing support and technical support services supplied to a foreign recipient under a master service agreement constituted &quot;intermediary services&quot; under s.2(13) of the IGST Act, thereby disentitling refund of accumulated input tax credit. On construing the agreement and contemporaneous records, the HC held the supplier was providing services on its own account and not arranging or facilitating supply between third parties; the supplies therefore qualified as export of services. Consequently, the adjudication and appellate orders treating the supplies as intermediary and raising IGST demand were quashed, and the tax authorities were directed to grant/sanction the claimed refund.</description>
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