Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as reservation services.

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....Pure-agent exclusion under Rule 33 requires satisfaction of every prescribed condition, including contractual authority to procure third-party services on the end customer's behalf. Hotel booking charges could not be excluded where the third-party booking agent invoiced the facilitator, indicating that it received and used the service in supplying its own hotel booking service, and where the recovered amount included a service charge not known to or authorised by the customer. The booking service is classified under SAC 998552 as reservation services for accommodation, cruises and package tours. CGST and SGST apply at 9% each on the entire consideration received from end customers.....