https://www.taxtmi.com/caselaws?id=788492 An Indian entity that only sponsors, coordinates, arranges permissions for, and administratively supports clinical trials conducted by independent hospitals and doctors is characterised by its real substance, not as the direct provider of clinical trial services. On the documented facts, the entity lacked its own manpower and infrastructure to conduct trials and merely facilitated third-party investigators while keeping the overseas principal informed. Because the actual conduct and supervision of the trials remained with the hospitals or investigators under the Drugs and Cosmetics Rules, 1945 and Schedule Y, the activity was treated as support services to the overseas principal rather than intermediary services or taxable clinical trial services in India. The Revenue's contrary demand was therefore not sustained. en-us Tue, 17 Mar 2026 00:00:00 +0530 Tue, 24 Mar 2026 08:12:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=788492 An Indian entity that only sponsors, coordinates, arranges permissions for, and administratively supports clinical trials conducted by independent hospitals and doctors is characterised by its real substance, not as the direct provider of clinical trial services. On the documented facts, the entity lacked its own manpower and infrastructure to conduct trials and merely facilitated third-party investigators while keeping the overseas principal informed. Because the actual conduct and supervision of the trials remained with the hospitals or investigators under the Drugs and Cosmetics Rules, 1945 and Schedule Y, the activity was treated as support services to the overseas principal rather than intermediary services or taxable clinical trial services in India. The Revenue's contrary demand was therefore not sustained. Case-Laws Service Tax Tue, 17 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=788492