Place of provision rule: sea transport to customs for transhipment is not taxable as destination lies outside the domestic territory. Under Section 66B and Section 66C and rule 10 of the Place of Provision of Services Rules, the place of provision for sea transportation is the destination of the goods; where import documentation and customs transhipment procedures identify the ultimate destination as a country outside the domestic territory and goods are transhipped accordingly, the transportation service to the customs station is not within the taxable territory and is not subject to service tax.