The Court reiterated that an 'intermediary' is one who merely 'arranges or facilitates' a supply, whereas the respondent was directly supplying marketing and consultancy services to the foreign universities, who were the recipients and payors of the commission

The Gauhati High Court has set aside a service tax demand order amounting to ₹16.37 lakh issued without proof of service of the show-cause notice, directing the authorities to furnish the notice afresh and grant the petitioner an opportunity to respond before passing a new order.

The concessional rate benefit cannot be availed for HSD utilized or resold beyond direct mining operations and upheld the tax authorities’ orders denying Form-C issuance