Export of Services vs Intermediary Under GST - Principal-to-Principal Service Contracts Qualify as Export of Services

Last updated: 06 October 2025

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The Rajasthan High Court has ruled that services provided under a principal-to-principal agreement, where the provider acts on their own account without facilitating for a third party, are considered an export of services. This decision clarifies that such arrangements do not fall under the definition of 'intermediary services' as per the IGST Act. Consequently, the petitioner is entitled to an IGST refund.

Court :
Rajasthan High Court

Brief :
The Hon'ble Rajasthan High Court in the case of IDP Education India Pvt. Ltd. v. Union of India & Ors. [Civil Writ Petition No. 9933/2024, order dated September 04, 2025] held that services rendered by the Petitioner to IDP Australia under a bi-partite agreement, without any contractual relationship with students, do not qualify as intermediary services under Section 2(13) of the IGST Act. Consequently, these services qualify as "export of services" and the Petitioner is entitled to IGST refund.

Citation :
Civil Writ Petition No. 9933/2024, order dated September 04, 2025

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Attached File : 671907_5879_idp_education_india_pvt_ltd.pdf

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Judgement posted by

Bimal Jain

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FCA, FCS LLB with21 Yrs of Experience inTaxation Indirect and Direct: Education Qualification: B.Com (Hons) Chartered Accountants Company Secretary LLB Qualified SAP FI/CO Consultants Professional Membership: Chairmanof Indirect Tax Committee of PHD Chamber of Commerce Member of Indirec ... Read more

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