https://www.taxtmi.com/caselaws?id=467488 The appeal raised legal questions on taxability and characterization of services under the Place of Provision Rules and Service Tax Rules; precedents on substantive classification and place-of-provision were applied and the appeal is dismissed, favouring the assessee. On whether the provider was an intermediary under the Rule 2(f) definition, the court held that a supplier rendering services on its own account is not an intermediary and that the contractual recipient and payment obligation determine the recipient for place-of-provision purposes; consequently the services qualify as export under Rule 6A and the impugned demand is unsustainable. en-us Mon, 24 Nov 2025 00:00:00 +0530 Thu, 19 Mar 2026 12:26:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=467488 The appeal raised legal questions on taxability and characterization of services under the Place of Provision Rules and Service Tax Rules; precedents on substantive classification and place-of-provision were applied and the appeal is dismissed, favouring the assessee. On whether the provider was an intermediary under the Rule 2(f) definition, the court held that a supplier rendering services on its own account is not an intermediary and that the contractual recipient and payment obligation determine the recipient for place-of-provision purposes; consequently the services qualify as export under Rule 6A and the impugned demand is unsustainable. Case-Laws Service Tax Mon, 24 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467488