Rule 4(a) Limits in Service Export: Importance of Tangible Presence Over 'Deemed Goods' in Place of Provision Rules 2012.

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....Export of service - Place of performance / supply of service - The deviation in rule 4(a) of Place of Provision of Service Rules, 2012 and, considering the specific circumstance of determination by tangible presence, it would not be amenable to stretching for coverage of ‘deemed goods’, if any, owing to that limitation of pinpointing ‘service’ which is of essence in the said Rule.- AT....