29 July 2019
In the Intermediary services, there are 2 supplies. One is between principal and agent and one is between principal and end customer. Is there any restrictions to say that the supply between principal and end customer should be taxed in India, then only treated as intermediary? or there is no relevance of supply between principal and end customer(even if the principal and end customer is outside India and supply is also outside India)??
30 July 2019
There is no relevance of supply between principal and end customer(even if the principal and end customer is outside India and supply is also outside India). In case of specific provisions of the ‘place of supply’, affecting the ‘intermediary services’, the place of supply shall be location of the supplier of services and hence it being the sole reason that ‘intermediary services’ cannot be classified as ‘export of services’ resulting thereby that the benefits available under ‘export of services’ cannot be availed by the intermediary service provider.