Inspection services provided in India for foreign client will not be treated as exports: AAR

Case Details: Authority for Advance Rulings, Telangana International Inspection Services (P.) Ltd., In re - [2022] 136 taxmann.com 214 (AAR- TELANGANA)

Judiciary and Counsel Details

• • B. Raghu Kiran and S.V. Kasi Visweswara Rao, Member

Facts of the Case

The applicant was performing inspection services for its foreign client during manufacturing of equipment and packing of equipment/material in India. It would be certifying quality and quantity of goods being supplied by Indian suppliers to foreign client. It filed an application for advance ruling to determine whether services rendered for foreign companies which do not have any business place/agency in India would be considered as an export or not.

AAR Held

The Authority for Advance Ruling observed that recipient of services provided by the applicant would be foreign buyer of Indian goods. The applicant would be performing services in relation to goods located or under manufacture in the territory of India on behalf of the foreign buyer. As per Section 13(3) of IGST Act, 2017, the place of supply shall be the location where the services are actually performed in respect of goods. Therefore, the services provided by the applicant would not be treated as exports and liable to CGST and SGST.