Levy of GST — Authority for Advance Ruling —Online Supply of Service– The applicant is an Indian private limited company set up under Indian Companies Act. This company is 100% Subsidiary of the company based in Israel. The R2Net Company has an agreement with customers for listing Diamonds online on their website. R2Net has appointed the applicant for photography service. The applicant takes photos of diamonds and upload photos of diamond on software of company based in Israel and charges from that company for providing above service of photography. The applicant does not give copy of photos to customers of R2Net and does not charge any fees to customers of R2Net. R2Net has given link of software through which Customer can view photos but they cannot download photo from software. The applicant sought an advance ruling as to whether the supply of photography service is liable to SGST under the Act, 2017(ii) or is it a zero rated “export” supply within the meaning of Section 2(23) r/w Section 2(6) of the IGST Act, 2017.
Held that:- The Hon’ble Authority for Advance Ruling held that the location of the supplier of service is in Mumbai and the place of supply as determined as per provisions of Act is also in Mumbai, a place where the services are actually performed. And therefore the services shall be treated as intrastate supply and would be liable to tax under the provisions of the Act. Further held that impugned supply is not export of services within the scope of section 2(6) of the IGST Act.Segoma Imaging Technologies India Private Limited  3 TAXLOK.COM 90 (AAR-MAHARASHTRA)