https://www.taxtmi.com/caselaws?id=784290 Services rendered by the assessee to foreign affiliates were assessed to GST on the premise that they were not export of services, and consequential denial of ITC, interest and penalty was imposed. Relying on para 3.2 of Circular No. 209/1/2018-ST, the HC held that for software-related services including testing, debugging, modification and allied data management functions, the place of provision is the location of the service recipient. On construing the master service agreement and the nature of activities as data management services covered by the circular, the HC held that GST demand on such services was unsustainable and quashed the impugned orders; the petition was allowed. en-us Mon, 08 Dec 2025 00:00:00 +0530 Thu, 01 Jan 2026 08:18:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784290 Services rendered by the assessee to foreign affiliates were assessed to GST on the premise that they were not export of services, and consequential denial of ITC, interest and penalty was imposed. Relying on para 3.2 of Circular No. 209/1/2018-ST, the HC held that for software-related services including testing, debugging, modification and allied data management functions, the place of provision is the location of the service recipient. On construing the master service agreement and the nature of activities as data management services covered by the circular, the HC held that GST demand on such services was unsustainable and quashed the impugned orders; the petition was allowed. Case-Laws GST Mon, 08 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784290