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2019 (2) TMI 1005 - AAAR - GSTPlace of supply - sourcing (on a worldwide basis)) of goods from India - export or not - Challenge to Advance ruling decision - Non-speaking order - It is pleaded that the Ld. AAR has not applied mind while passing the impugned order and the order is non-speaking. Held that:- It is observed that the appellant is side tracking the facts by submitting that the appellant is not an agent or broker, as no such question was asked before the AAR - The Id. AAR has answered all the Questions raised, in term of relevant provisions of the GST Act and by giving detailed reasons. The plea of the appellant, that the AAR has given SAC & description alongwith tax rate which was not asked for, does not hold water because AAR has clarified each and every aspect raised in the application for Advance Ruling by giving self-explanatory findings. Thus the arguments raised by the appellant are untenable. The appellant has himself admitted that he has been providing services to the Esprit Germany in terms of the contract between Esprit Germany and Esprit Hong Kong and for that purpose an agreement was made between Esprit Hong Kong and Esprit India (appellant). The appellant is providing the services of market research and assisting in trade mark protection, identification of supplies and inspection and quality control of the goods/services. Therefore, we find that the AAR has rightly identified the SAC description with rate of tax - After perusing the provisions of Section 97(2) and going through the findings of AAR, we are of the view that Question 2 and 3, raised by the applicant, have rightly been declined by the AAR. There is no hesitation in dismissing the appeal - the Advance ruling decision does not suffer from any infirmity or illegality and the same is upheld.
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