Student recruitment commissions held export of services, not intermediary services, under Rule 2(f), Rule 6A and Section 13(2).

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....HC examined whether Respondent's activities in recruiting students for foreign universities constituted "intermediary services" under Rule 2(f) of the POPOS Rules or export of services under Rule 6A of the Service Tax Rules, 1994. Noting that Respondent earned commission in foreign exchange for services rendered to foreign universities, HC applied the ratio of Ernst & Young Ltd, clarifying that only a person arranging or facilitating the supply is an intermediary and that place of supply for such services is governed by Section 13(2) IGST Act. Holding that the Adjudicating Authority's characterization was erroneous and that the services qualified as export, HC upheld the impugned order and dismissed the appeal.....