https://www.taxtmi.com/caselaws?id=797265 Services performed by an Indian branch for external commercial borrowing facilities booked by its Singapore head office were not intermediary services. As the branch and head office were the same legal person, their internal activities could not constitute services between separate persons. Intermediary status also requires three parties, an identifiable main supply between two principals, and a distinct ancillary facilitation service. The Indian office undertook origination, structuring, credit assessment and monitoring on its own account, while the head office contracted for and bore the credit risk. Its remuneration was not consideration for facilitating supplies to borrowers. Rule 3 governed place of provision, rather than Rule 9(c), so no service-tax liability or consequential penalties arose. en-us Mon, 17 Aug 2026 00:00:00 +0530 Thu, 20 Aug 2026 08:14:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797265 Services performed by an Indian branch for external commercial borrowing facilities booked by its Singapore head office were not intermediary services. As the branch and head office were the same legal person, their internal activities could not constitute services between separate persons. Intermediary status also requires three parties, an identifiable main supply between two principals, and a distinct ancillary facilitation service. The Indian office undertook origination, structuring, credit assessment and monitoring on its own account, while the head office contracted for and bore the credit risk. Its remuneration was not consideration for facilitating supplies to borrowers. Rule 3 governed place of provision, rather than Rule 9(c), so no service-tax liability or consequential penalties arose. Case-Laws Service Tax Mon, 17 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797265