Marketing Services Not Qualifying as Export When Goods Are in Supplier's Location, Per Section 13(3)(a) Regulations.

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....Export of service or not - the marketing services are provided in respect of goods which are made physically available by the recipient of services (i.e. IIUL through its distributors) to the supplier of marketing services (i.e. the appellant), in order to provide the services. Therefore, as per Section 13(3)(a), the place of provision of service is the location of the supplier of services i.e. the applicant, which is in India. - the impugned supply does not qualify as export of services. - AAAR....