[krogothwolf]

I don't think that's the case though, you do have things that are obviously blatant fan service. You see the girls with the giant breasts and then when an article of clothing gets cut off it draws attention to it. That does seem to happen a lot in anime's that are less serious and more about Fan Service and goofing off. If the show is needlessly drawing attention to portions of the female body while the cloths get destroyed the purpose is fan service. You don't need to show a close up of the top of the shirt getting sliced to show the cleavage, you could just have it fall off when the character jumps back or during the fight.

It's the quality and type of show that your watching that'll determine if a girl fighting is designed for fan service.