https://www.taxtmi.com/caselaws?id=788313 Assignment of employees to foreign group companies on an on-site basis qualifies as export of service where the recipient is located abroad and the benefit of the service accrues outside India; physical performance in India is not determinative. The legal analysis applies Export of Service Rules and the Finance Act construct that export status depends on recipient location and accrual of benefit, and accepts non-written agreements supported by invoices and receipt in convertible foreign exchange as evidencing the contractual relationship. Operative effect: such services are treated as exports and not liable to service tax under the facts described. en-us Thu, 19 Mar 2026 00:00:00 +0530 Fri, 20 Mar 2026 08:35:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=788313 Assignment of employees to foreign group companies on an on-site basis qualifies as export of service where the recipient is located abroad and the benefit of the service accrues outside India; physical performance in India is not determinative. The legal analysis applies Export of Service Rules and the Finance Act construct that export status depends on recipient location and accrual of benefit, and accepts non-written agreements supported by invoices and receipt in convertible foreign exchange as evidencing the contractual relationship. Operative effect: such services are treated as exports and not liable to service tax under the facts described. Case-Laws Service Tax Thu, 19 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=788313