GST on Support Services to Japanese Company: Place of Supply is Vessel Location, Affects Export Status.

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....Levy of GST - distinct person - support services - Export of services or not - place of supply of service - In the present case, the applicant is a company incorporated under the laws of India and the service recipient group company, NSKJ is incorporated under the laws of Japan and therefore are separate persons and would not be considered as “merely establishments of distinct persons”. - the “Place of Supply” of the service extended will be the place of availability of the vessel and not the place of service receiver, i.e., NSKJ, which is Japan. - AAR....