Courier transshipment of imported goods via named carrier to air cargo stations renewed until 30.01.2026; exemption conditional, strict controls apply...
Insurer's investment gains and investment write-downs face Section 263 revision; enquiry upheld, Rule 5(b)(ii) lapse sustained, late corrigendum quash...
The article addresses whether pre-clinical R&D and testing services performed in India for foreign recipients qualify as export of services under the place-of-supply framework. It concludes that supplied samples/reference materials used in testing are not 'goods' attracting the place-of-performance exception, so the general place-of-supply rule applies and the location of the foreign recipient governs; consequently such services are not taxable in India when export conditions are met. It further finds that the clarificatory notification and amendment operate retrospectively as beneficial clarification, entitling the taxpayer to relief and justifying quashing of the impugned show-cause notices for the stated periods.
The article addresses whether pre-clinical R&D and testing services performed in India for foreign recipients qualify as export of services under the place-of-supply framework. It concludes that supplied samples/reference materials used in testing are not 'goods' attracting the place-of-performance exception, so the general place-of-supply rule applies and the location of the foreign recipient governs; consequently such services are not taxable in India when export conditions are met. It further finds that the clarificatory notification and amendment operate retrospectively as beneficial clarification, entitling the taxpayer to relief and justifying quashing of the impugned show-cause notices for the stated periods.
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