Place of performance of service is decisive for determining event of taxability as well as incidence of tax

The appellant appears to have performed service in India for ultimate consumption thereof in India by its clients/customers in India. The service is destined to exhaust in India and extinct soon after performance thereof. Post performance liability only remains to be discharged by foreign principal through the appellant in India. Thus the beneficiaries of services were located in India for ultimate consumption of the service provided in India.

The services provided by the appellant were only to benefit the consumers of Indian

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