Place of supply rules clarified: port cargo services follow contractual service-place rules; exported-after-treatment services follow temporary-import exception. Cargo-handling activities by port authorities are ancillary services not related to immovable property; their place of supply is determined under the contract-based service rules applicable between supplier and recipient. Services performed on goods temporarily imported and exported after treatment without being put to use fall under the exception for temporarily imported goods, and their place of supply is determined by the provision addressing such exported-after-treatment services.
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Provisions expressly mentioned in the judgment/order text.
Place of supply rules clarified: port cargo services follow contractual service-place rules; exported-after-treatment services follow temporary-import exception.
Cargo-handling activities by port authorities are ancillary services not related to immovable property; their place of supply is determined under the contract-based service rules applicable between supplier and recipient. Services performed on goods temporarily imported and exported after treatment without being put to use fall under the exception for temporarily imported goods, and their place of supply is determined by the provision addressing such exported-after-treatment services.
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