Export eligibility in case of service

Query
There is a development of marketing content that is required to be done.
- Parties Involved in the Transaction
- Group Company ( Situated in China)
- Holding Company (Situated in China)
- ABC CO. (Located in India)

- Scenario

1. Group company has given order to holding company for developing marketing content for India market.

2. Holding Company approached to ABC Co. to develop the content.

Whether the above transaction qualifies for the "Export of Service" or not ?
If yes then please states the conditions under which we can consider this transaction as an Export of Service??

Note : Developed content will be utilised in Indian market .
Replies (6)
Kindly clarify :

from whom the Indian company getting payment ?????

& to whom the Indian company going raise bill.

As Per Section 7(5) of IGST Act

Supply of Goods & Service Both When the Supplier Located in India and Place of supply is located outside India 

In Case of Scenario 

1 There is No Question arise related to  Export Service in First Scenario because both Party outside India 

2- In Second case Place of Supply is within India and Supplier is also in India 

Therefore in second case also no export service as Per section 7(5) read with section 5 of IGST Act 2017 

Holding company will make payment to ABC Co.
Dear Ashutosh

can plz clarify one more point in regard to your query that , how this "development of Marketing content being provided by Indian co. , I mean whether it's an kind of soft copy being sent via electronic media (ie computer) to Holding co. ???
You can consider it electronically
As per definition of Export Services vide section 2(6) read with Section 13(12) of IGST Act , it's qualified as export .

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