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    <title>2026 (1) TMI 519 - CESTAT KOLKATA</title>
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    <description>Services of identifying and counselling students for admission in foreign educational institutions were treated as substantive services rendered to overseas universities and colleges, not as facilitation of another person&#039;s supply. Because the activity was performed for foreign recipients, consideration was received in convertible foreign exchange, and no three-party brokerage or facilitation structure was shown, the arrangement did not satisfy the test for intermediary services. The service provider acted on its own account for the overseas recipients rather than as a conduit between two other parties. The services were therefore export of services and service tax was not leviable.</description>
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      <description>Services of identifying and counselling students for admission in foreign educational institutions were treated as substantive services rendered to overseas universities and colleges, not as facilitation of another person&#039;s supply. Because the activity was performed for foreign recipients, consideration was received in convertible foreign exchange, and no three-party brokerage or facilitation structure was shown, the arrangement did not satisfy the test for intermediary services. The service provider acted on its own account for the overseas recipients rather than as a conduit between two other parties. The services were therefore export of services and service tax was not leviable.</description>
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