Business Auxiliary services provided by Indian subsidiary directly to foreign holding company are export of services

GST/Excise/ST/VAT : Where assessee, a subsidiary of its holding company 'ATI' located abroad, which was in turn a subsidiary of AMD Inc., USA, was a 100 per cent software export oriented unit and it provided business auxiliary service to its holding company under master services agreement and said agreement did not provide that assessee would facilitate or arrange purchase and sale on behalf of AMD entities outside India, service rendered by assessee was in nature of export of service

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