SMS Aggregator Services Exported to Ireland; Indian Subscribers Not Recipients, Rule 8 Inapplicable for Non-Taxable Territory.

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....Export of services - providing SMS Aggregator services to facebook, Ireland - the Indian subscribers of Facebook cannot be termed as Service Recipient - In such case even the Rule 8 of POP would not apply as the service recipient i.e Facebook is situated in Ireland which is located outside India a non taxable territory. - AT....