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The specified transaction do not qualifies the export of service because all the conditions which are stipulated under Section 2(6) of IGST Act, 2017 are not satisfied which is the foremost requirement for any transaction to be qualified “Export of Service”.

Classification of service— In the instant case, the applicant is supplier of products in textile and graphics printing market and engaged in manufacturing of Rotary screen printing machine and also offer products for conventional and digital engraving methods. The applicant have entered into a contract with SPG Prints Austria GMBH (herein after referred as ‘SPA’) to provide particular services to customers of SPA in India, as per SPA’s instruction. Such services shall include installation / up-gradation of machines sold by SPA, training at SPA’s customers’ site etc. the Applicant sought the Advance Rulings on the following questions on the specified transaction: Question 1. Whether, in the facts and circumstances, the specified transaction of the Applicant should be categorized as individual supply or composite supply of service as per the Central Goods and Services Tax Act, 2017 and the Gujarat Goods and Services Tax Act, 2017? Question 2. Whether, in the facts and circumstances, the specified transaction of the Applicant is to be reckoned as being provided to SPA or to the customers of SPA located in India? Question 3. - Whether, in the facts and circumstances, the specified transaction of the Applicant could be categorized as that of an “intermediary” as per Section 2(13) of The Integrated Goods and Service Tax Act, 2017? Question 4. - Whether, in the facts and circumstances, the specified transaction qualifies to be “Export of service” as per Section 2(6) of The Integrated Goods and Services Tax Act, 2017? Held that— The specified transaction of the Applicant is a composite supply of service as per the Central Goods and Services Tax Act, 2017. The person i.e. Indian customer to whom service is supplied in India. The specified transaction of the Applicant is categorized as an “intermediary” as per Section 2(13) of The Integrated Goods and Service Tax Act, 2017. we members of the authority conclude that the specified transaction do not qualifies the export of service because all the conditions which are stipulated under Section 2(6) of IGST Act, 2017 are not satisfied which is the foremost requirement for any transaction to be qualified “Export of Service”.
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