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<h1>Education consultancy commissions treated as exportable services, not intermediary services, where foreign institution is the contracting recipient.</h1> The Court held that the intermediary test focuses on whether a person merely 'arranges or facilitates' a supply, excluding those who supply on their own account; where agreements and consideration establish a principal-to-principal supply to foreign educational institutions, the services qualify as export of services and not intermediary services, making place of supply the recipient's location and supporting refund entitlement.
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