In circular no. 118/2019-GST, the CBIC has clarified that place of supply of software / design by supplier located in taxable territory to service recipient located in non-taxable territory by using sample prototype hardware / test kits n a composite supply, where such testing is an ancillary supply, is the location of the service recipient as per section 13(2) of IGST act.
To read the circular, click here circular-cgst-118
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