Place of supply: ancillary prototype testing treated as recipient-location supply under IGST place-of-supply rules. When testing on recipient-provided prototype hardware is ancillary to the principal design/software supply in a composite contract, the place of supply is the location of the service recipient under the IGST place-of-supply rule for services supplied to non-taxable territory recipients; the provision regarding goods made physically available does not apply separately to ancillary testing.