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    <title>2026 (5) TMI 3 - CESTAT BANGALORE</title>
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    <description>Marketing support services supplied to an overseas entity were held not to constitute intermediary services under the Place of Provision of Services Rules, 2012 because the provider acted on a principal-to-principal basis, had no authority to bind the foreign recipient, and could not accept or reject orders on its behalf. The services were limited to pre-sales support and information, with customer orders placed directly in the foreign entity&#039;s name. As the intermediary definition was not attracted, the place of provision remained the recipient&#039;s location outside India under Rule 3, and the services qualified as export of service. The service tax demand could not be sustained.</description>
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