Scenario | Fact of the case | Clarification under circular |
Scenario-I | Where supplier located in India supplies ITeS to overseas client or customer of his client on his own account. | Supplier is Not an Intermediary, since the services are provided on his own account, not on behalf of client, even if supplier is considered as an agent. |
Scenario-II | Where supplier of backend services located in India arranges/facilitates supply by foreign client to customers of client, for example provisioning of services like, order placement, delivery, logistic support, govt. approvals, post-sale support etc.) | Supplier is an Intermediary, since he is merely arranging or facilitating the supply of goods or services or both between two or more persons. |
Scenario-III | Both the services mentioned above are provided as a package. | Shall Depend on Case to Case basis, by determining that which set of service is principle/main supply. |