Applicability of service tax on the services by way of transportation of goods by a vessel from a place outside India to the customs station in India w.r.t. goods intended for transhipment to any country outside India

Place of provision of services: sea transport to customs station for transhipment abroad lies outside India's taxable territory.

Transportation of goods by vessel to an Indian customs station is not taxable where the import manifest or report specifies transhipment to a foreign country and the goods are transshipped in accordance with the Customs Act and transhipment regulations, because the Place of Provision of Services is the destination outside India and thus outside the taxable territory.