I see. So basically, you are asking Sebi to define the definition of “service” here.
Hoping that you will get a clear/crisp answer from them 
(have my doubts). Please update their response whenever you get it.
In my experience, there are two aspects of any rule/law
- Definition of law: violate this and you will be in trouble
- Intent of law: you are not bound but you should respect this
A list of checks/patterns tracked over-time reveals if you were intentionally violating the intent of the law. It’s very hard to say if one will get into trouble or not for violating intent. In the short term, you may or may not get away with it. In the long term, you will run into issues. So at times, it’s better to understand the intent rather than just the definition.
I am guessing you would have already read about the new rules SEBI is building for influencers. This should tell you what direction is SEBI could be heading into.
Source: Worked in legal teams for two market-leading startups in India.
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