https://www.taxtmi.com/caselaws?id=795563 Intermediary services under the Place of Provision of Services Rules, 2012 require a person to arrange or facilitate a main supply between two or more persons in an agent-like role; a supplier acting on its own account is excluded. The article notes that services rendered on a principal-to-principal basis, including support, technical, manufacturing and administrative services, do not become intermediary services merely because they benefit third parties at the overseas recipient's request. Contractual restrictions on negotiating or concluding sales, together with cost-plus remuneration unrelated to sales, support treatment as own-account services. The services therefore qualify as export of services rather than intermediary services, making service tax demand and penalties unsustainable. en-us Mon, 20 Jul 2026 00:00:00 +0530 Fri, 24 Jul 2026 08:36:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795563 Intermediary services under the Place of Provision of Services Rules, 2012 require a person to arrange or facilitate a main supply between two or more persons in an agent-like role; a supplier acting on its own account is excluded. The article notes that services rendered on a principal-to-principal basis, including support, technical, manufacturing and administrative services, do not become intermediary services merely because they benefit third parties at the overseas recipient's request. Contractual restrictions on negotiating or concluding sales, together with cost-plus remuneration unrelated to sales, support treatment as own-account services. The services therefore qualify as export of services rather than intermediary services, making service tax demand and penalties unsustainable. Case-Laws Service Tax Mon, 20 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795563