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    <description>Services rendered on own account to foreign universities were held not to be intermediary services under the Place of Provision of Services Rules, 2012. The Tribunal applied settled precedent that earning commission does not by itself make a provider an intermediary where the activity is direct service to an overseas client rather than facilitation between two persons. The services were treated as export of service and, on that basis, the service tax demand, interest and penalty were unsustainable.</description>
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