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GST Levied on Maintenance and Repair Contracts for Machinery; MARC Holder Liable Under IGST Act Sections 2(11) and 12(2)(a).

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....Levy of GST - Maintenance and Repair Contract with respect to the machinery and equipment it had supplied - Supply of the MARC Holder to BCCL is not import of service within the meaning of section 2 (11) of the IGST Act. The MARC Holder should be treated as a supplier located in India triggering clause 9.2.2 of the MARC, and made liable to pay GST, the place of supply being determined in terms of section 12 (2) (a) of the IGST Act.....