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    <title>2026 (4) TMI 668 - KARNATAKA HIGH COURT</title>
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    <description>Pervasive control, economic dependence, disciplinary oversight, deposit requirements and regulated termination showed that pigmy agents functioned as employees of the bank rather than independent service providers. On that basis, services rendered in the course of employment fell within Section 7(2)(a) read with Schedule III of the CGST Act and were outside GST, so a tax demand treating the agents as business facilitators could not stand. The bank&#039;s characterisation of the arrangement as an intermediary or correspondent model was rejected, because the actual role was confined to deposit collection under the bank&#039;s scheme. The show cause notices founded on GST liability were therefore unsustainable.</description>
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