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The appellant performed clinical study services in India on drugs supplied by their foreign client and delivered the clinical study report through email, courier, or website. The department argued that since the service was performed in India on goods supplied by the recipient, it did not qualify as export of service u/r 4 of the Place of Provision of Service Rules, 2012. However, relying on previous judgments in Sai Life Sciences Ltd. and Fertin Pharma Research & Development India Pvt. Ltd., it was held that conducting clinical trials on drugs supplied by a foreign service recipient and providing the technical report constitutes export of service u/r 3 of the Rules, 2012. Therefore, such services are not liable to service tax. The impugned order was set aside, and the appeal was allowed.
The appellant performed clinical study services in India on drugs supplied by their foreign client and delivered the clinical study report through email, courier, or website. The department argued that since the service was performed in India on goods supplied by the recipient, it did not qualify as export of service u/r 4 of the Place of Provision of Service Rules, 2012. However, relying on previous judgments in Sai Life Sciences Ltd. and Fertin Pharma Research & Development India Pvt. Ltd., it was held that conducting clinical trials on drugs supplied by a foreign service recipient and providing the technical report constitutes export of service u/r 3 of the Rules, 2012. Therefore, such services are not liable to service tax. The impugned order was set aside, and the appeal was allowed.
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