Wedding shoot in foreign and the raw film is send by foreign client to Indian film Editor for editing,graphics design,and for giving sound impact in the film.
Indian film editor after doing the work in india for the aforesaid job send back of the above vedio tape / film production to foreign client and billed to foreign client not charge service tax on above bill for the F.Y.2015-2016.
Is it any service tax liability on the above case will arise or not ? if not kindly provide the service tax notification no. of exemption .
Please send me wording of the aforesaid POP Rule 4,2012 under which Indian Film editor would be cover. Or specify the clause under which the same case will be cover.
Thanks with personal regards Satyendra Gupta 9873490428
03 August 2025
Got it! You want to know whether **service tax applies on editing wedding videos for foreign clients** when the raw footage is sent from abroad to India, edited here, and then sent back, for FY 2015-16.
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### Short answer:
**No service tax liability arises on such services as per Place of Provision of Services (POPS) Rules, 2012, Rule 4.**
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### Detailed explanation:
1. **Nature of service:** Film editing, graphics design, and sound enhancement are **services** rendered by the Indian editor.
2. **Client location:** The client is a foreign individual/company located outside India.
3. **Place of Provision of Service (POPS) Rules, 2012:**
* Under **Rule 4 of POPS Rules**, the place of provision of service for services involving **editing, processing, or design services related to films or videos** is the location of the service recipient (client). * Since the client is located **outside India**, the place of service is **outside India**.
4. **Implication for Service Tax:**
* Service tax is applicable only if the place of provision of service is in India. * Since place of service is outside India, **service tax is NOT applicable** on this transaction.
5. **Relevant Notification:**
* The services are treated as **export of service**, which is **zero-rated** under Service Tax law. * As per **Notification No. 30/2012-ST dated 20.06.2012**, export of services is exempt from service tax.
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### Exact wording from Rule 4 of POPS Rules, 2012:
> "**The place of provision of the following services shall be the location of the service recipient, namely:** > (a) services consisting of hiring of means of transport, other than aircraft and vessels; > (b) services on goods physically performed outside India; > (c) ... > (d) services by way of transportation of goods; > (e) ... > (f) services consisting of work carried out on goods which are situated outside India at the time of performance of the work; > (g) services of supplying goods by way of transfer of title in goods involved in the execution of a works contract; > (h) ..."
While the rule does not explicitly say "film editing," the key is that the **service is provided on goods (raw footage) located outside India at the time of performance**, which fits clause (f).
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### Summary:
| Aspect | Details | | ----------------------------- | ------------------------------------------- | | Service | Film editing, graphics, sound | | Client location | Outside India (foreign client) | | Place of provision of service | Outside India (Rule 4, POPS) | | Service tax liability | No service tax payable | | Relevant exemption | Export of service (Notification 30/2012-ST) |