An activity between only 2 parties cannot be treated as intermediary service

BlackRock Services India Private Limited Vs Commissioner of CGST (CESTAT Chandigarh) The term “intermediary” has been defined under Rule 2(f) of Place of Provision of Services Rules, 2012 which is reproduced as under:- “intermediary” means a broker, an agent or any other person, by whatever name called, who arranges or facilitates a provision of a service (hereinafter called the „main‟ service) or a supply of goods, between two or more persons, but does not include a person who provides the main service or supplies the goods on his account”. A plain reading of the aforesaid provi...