https://www.taxtmi.com/caselaws?id=794211 Services performed for an overseas client's customers under a principal-to-principal subcontract were not intermediary services because there was no contractual nexus with those customers and remuneration came only from the overseas client. Applying the jurisdictional High Court's treatment of the same agreement structure and the departmental clarification that the intermediary concept is similar under the service tax and GST regimes, the services were treated as export of services. The place of provision did not shift to India, so export benefit was not denied and refund of accumulated Cenvat credit under Rule 5 was allowable. en-us Wed, 01 Jul 2026 00:00:00 +0530 Thu, 02 Jul 2026 08:07:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794211 Services performed for an overseas client's customers under a principal-to-principal subcontract were not intermediary services because there was no contractual nexus with those customers and remuneration came only from the overseas client. Applying the jurisdictional High Court's treatment of the same agreement structure and the departmental clarification that the intermediary concept is similar under the service tax and GST regimes, the services were treated as export of services. The place of provision did not shift to India, so export benefit was not denied and refund of accumulated Cenvat credit under Rule 5 was allowable. Case-Laws Service Tax Wed, 01 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794211