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Similarly, persons such as call centers, who provide services to their clients by dealing with the customers of the client on the client's behalf, but actually provided these services on their own account', will not be categorized as intermediaries.

Applicant relying on above paragraph submitted that call centers, by dealing with customers of their clients, on client's behalf, are providing service to their client on their own account. Similarly, applicant is providing business support service such as marketing and other allied services like oversight of quality of third party customer care centre operated in India and payment processing services, on behalf of GoDaddy US. Therefore, these services provided by the applicant to GoDaddy US cannot be categorized as intermediary or services, as intermediary service.

11. Applicant proposes to provide support services in relation to marketing, branding, offline marketing, oversight of quality of third party customer care centre and payment processing, on principal to principal basis. These services are proposed to be provided with the sole intention of promoting the brand GoDaddy US in India and thus augmenting its business in India. Therefore, these services proposed to be provided by the applicant, would support the business interests of GoDaddy US in India.

12. It has been submitted by the applicant that services to be provided by the applicant are not peculiar only in applicant's case but are provided by various Indian entities to their overseas customers in India as a single package. Further, supporting the business of GoDaddy US in India is the main service and processing payments and oversight of services of third party Call Centers are ancillary and incidental to the provision of main service, i.e., business support service. Further, applicant would provide said services as a package and the payment for the entire package would be a consolidated lump sum payment. Applicant submits that in view of all these indicators, service provided by them to GoDaddy US is a bundle of services, which is bundled in normal course of business. This point has not been controverted by the Revenue. We agree with the submissions of the applicant that proposed services are a bundle of services, bundled in normal course of business and not intermediary service.

Reliance can also be placed on the ruling of Authority for Advance Ruling (Central Excise, Customs & Service Tax), New Delhi on the application of M/s. GoDaddy India Web Services Pvt. Ltd., vide Ruling No.AAR/ST/08/2016 in Application th No.AAR/44/ST/15/2014 dated 04 March, 2016. The ruling of the said application is explained in detail herein below: "....... Section 66F of the Finance Act,1994, read with rules 2(f), 3 and 9 of the Place of Provision of Service Rules, 2012 and Rule 6A of the Service Tax Rules, 1994 Service - Bundled Services - GoDaddy US, was a domain name register and web hosting service provider - Assessee was proposing to provide: (a) Marketing and Promotion services,