RCM ON FOREIGN BANK CHARGES - Goods and Services Tax - GST

Dear Expert - Observation raised by GST Officer During The Audit My Client is exporter, Importer Local Trader Observation : NON-PAYMENT OF RCM ON FOREIGN BANK CHARGES: During the course of Audit, It is seen that foreign bank have deducted the bank charges against receipt of foreign currency. The banks are deducting charges for remittance of money. The location of the supplier i.e. Bank is outside India and location of the recipient is in India (taxable territory). from the data provided. it is seen that a certain amount of charges are shown as short receipt which are actual the Bulk Charges of the foreign Bank. The Service provided by foreign bank for remittance to export proceeds is liable to GST as per Notification No. 10/2017-Integrated Tax (Rate), dated 27.06 2017 , which stipulates that any service supplied by any person who is located in a non-taxable territory to any person located in a non-taxable territory, the person located in the taxable territory will be paid on reverse charge basis by the recipient of such services---------------- is it RCM Applicable Please Guide