Place of provision of service

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Place of provision(POP) for Classroom teaching is to be determined as per Rule 4(b) of POP services rules , 2012. As per the said rule the POP will be place where services are actually performed i.e class room. What would be the POP in case of video coaching services in the following cases-
1. Rendered from non-taxable territory to service recepient situated in taxable territory.
2. Rendered from taxable territory to service recepient in non- taxable territory.

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as per my opinion in case of video lectures place of receipient would be considered and hence in 1st instance it would be liable to service tax and exempt in 2nd case


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