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AAR Rules R&D Services for Foreign Entities in Gujarat Not Zero-Rated, IGST Applicable Under Local Supply Criteria.

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....Levy of IGST - services provided by the applicant to the entities located outside India - zero rated supply or not - As the services provided by the applicant are in the form of R&D activity undertaken on the sample goods provided by the recipient i.e. the sample goods have to be made physically available by the recipient to the applicant in order to enable the applicant to provide the services. Therefore, the place of supply of service in the present case will be the location where the services are actually performed. The place of supply of services is therefore, Gujarat. - The subject services do not merit to be covered under Section 13(2), IGST Act. - AAR....