Place of supply: data hosting to overseas cloud providers is at the recipient, enabling export treatment. Data hosting supplied by an Indian data centre operator to overseas cloud computing providers is not an intermediary service, not a service in relation to goods made available by the recipient, and not a supply directly related to immovable property. The bundled, operational nature of data hosting-ownership and independent operation of premises, hardware, software, power, connectivity and security-means the place of supply defaults to the recipient's location; where the recipient is outside India the supply may be treated as export of services subject to export eligibility conditions.