The prototypes goods are made physically available by the recipient of services (the overseas clients) to the supplier of services (the applicant). Service of testing is over once on the basis of examination and verification of prototype, the test report is generated and sent via mail as stated by the applicant and therefore provision of testing service is over and the service is completed and is clearly provided in India as per section 13(3) of the IGST Act and
Therefore it can be inferred that the said services of testing of the prototypes, which are physically made available by the service receiver to the service provider, are provided in India and, therefore, liable to IGST and cannot be treated as zero rated supply.
AUTHORITY FOR ADVANCE RULINGS, MAHARASHTRA
Behr-Hella Thermocontrol India (P.) Ltd., In re
ORDER NO. GST/ARA/12/2018-19/B-116
SEPTEMBER 15, 2018