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GST – Tamil Nadu AAR - Classification of Services - Export of Service, Place of Supply of Support Service - Applicant propose to provide end-to-end services to the shippers located outside the Indian territory with respect to the vessels of such customers, when their vessels calls on the Indian Port – whether said support services provided by the applicant would qualify as export of services under SAC 9985 of Notification No. 11/2017-Central Tax (Rate) dated June 28, 2017 – HELD - applicant extends vessel related services, supporting the shipper to facilitate the entry/exit of the vessel in the Indian Ports, i.e., the services are more in the nature of ‘support services for transport of vessels' and more aptly will be classifiable under SAC 9967 - The said 'end-to-end' services proposed by the applicant covers all the services specified in this Group 99675, which also has an entry accommodating ‘other supporting service’ under 996759 - the entire gamut of services are towards bringing the vessel (goods) to the Port, enabling the vessel leave the port and undertaking repairs, requirements of the vessel and therefore, the services rendered by the applicant are intrinsically rely on the presence of the Vessel (goods) in the Indian territorial waters/port - the proposed services are rendered in respect of the vessels which are physically available in the Indian Territory and therefore, the proposed services are squarely covered under Section 13(3) of the IGST Act, accordingly, the place of supply of service in the location where the services are actually performed, which is the taxable territory - the proposed supply of the applicant is classifiable under SAC 9967 is taxable to 18% GST under sl.No. 11(ii) of the Notification No. 11/2017-C.T.(Rate) dated 28.06.2017 as amended
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