Place of Supply for custodial services: determined under default rule, not as services to an account holder. Custodial services by banks to Foreign Portfolio Investors are not services provided to an account holder and therefore the place of supply is not governed by the account-holder rule; instead, the place of supply must be determined under the default place-of-supply provision, which looks to the location of the service recipient where ascertainable and to the supplier otherwise.
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Provisions expressly mentioned in the judgment/order text.
Place of Supply for custodial services: determined under default rule, not as services to an account holder.
Custodial services by banks to Foreign Portfolio Investors are not services provided to an account holder and therefore the place of supply is not governed by the account-holder rule; instead, the place of supply must be determined under the default place-of-supply provision, which looks to the location of the service recipient where ascertainable and to the supplier otherwise.
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