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    <description>Business support services rendered to an overseas group entity on a principal-to-principal, cost-plus basis were not intermediary services because the provider did not arrange or facilitate supply between that entity and third parties. Under the Place of Provision of Services Rules, 2012, intermediary status applies only where a person facilitates a main service between two or more persons; mere assistance to the recipient&#039;s business on its own account is insufficient. As the place of provision was outside India, the service was not taxable in India and the demand for service tax, interest and penalties was unsustainable.</description>
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