Service tax applicability ?

Yes , as per rule 8 of place of provision of service rules,2012 where both service provider & service receiver is located in taxable territory but service is provided outside taxable territory then also Service tax will be applicable.

Rule 8 is applicable for an intermediary for services ONLY not for goods. Therefore in this case not applicable

In this case rule 3 would apply as marketing services and since the recepient is in India laible to ST. However an exemption is available upto 10% of FOB value of exports which can be claimed.

I am keeping this bookmarked as the issue has been addressed by learned FCA and ex CC member of ICAI Mr. Hiregange.

Regards,

Thank you so much sir for clearing my doubt. I am really obliged.