Place of supply rules: port cargo handling follows contract-based provisions; processing of temporary imports follows export exception. Clarification: cargo-handling services by ports are ancillary, not immovable-property related, so their place of supply is determined under sub-section (2) of Section 12 or sub-section (2) of Section 13 of the IGST Act depending on contractual terms. Services on goods temporarily imported for processing and exported without being put to other use (e.g., cutting and polishing of unpolished diamonds) fall under the temporary import/export exception and their place of supply is determined under sub-section (2) of Section 13 rather than the general performance-location rule.
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Provisions expressly mentioned in the judgment/order text.
Place of supply rules: port cargo handling follows contract-based provisions; processing of temporary imports follows export exception.
Clarification: cargo-handling services by ports are ancillary, not immovable-property related, so their place of supply is determined under sub-section (2) of Section 12 or sub-section (2) of Section 13 of the IGST Act depending on contractual terms. Services on goods temporarily imported for processing and exported without being put to other use (e.g., cutting and polishing of unpolished diamonds) fall under the temporary import/export exception and their place of supply is determined under sub-section (2) of Section 13 rather than the general performance-location rule.
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