India: Global procurement services from foreign group entity were not intermediary services for GST purposes (tribunal decision)
The GSTAT held that global procurement services received from a Swiss group entity constituted an import of services rather than intermediary services.
The Principal Bench of the Goods and Service Tax Appellate Tribunal (GSTAT) held that global procurement services received from a Switzerland-based group entity were not intermediary services under section 2(13) of the Integrated Goods and Services Tax (IGST) Act, 2017.
The case is: Dow Chemical International Private Limited, 2026-VIL-26-GSTAT-DEL
The GSTAT held that the Swiss entity was rendering substantive procurement services on its own account as a centralized procurement hub for the group and was not merely arranging or facilitating supply between the taxpayer and third-party suppliers.
Accordingly, the GSTAT concluded that the services constituted an import of services, the place of supply was in India under section 13(2) of the IGST Act, 2017, and that the taxpayer had correctly discharged IGST under the reverse-charge mechanism.
Read a June 2026 report prepared by the KPMG member firm in India