An architect based in Mumbai provides his service to an Indian hotel chain (which has business establishment in New Delhi) for its newly acquired property in Dubai. If Rule 5 (Property rule) of the Place of Provision of

An architect based in Mumbai provides his service to an Indian hotel chain (which has business establishment in New Delhi) for its newly acquired property in Dubai. If Rule 5 (Property rule) of the Place of Provision of Services Rules, 2012 were to be applied, the place of provision would be the location of the property, i.e., Dubai (outside the taxable territory). With this result, the service would not be taxable in India. Whereas, by application of Rule 8 of the above mentioned rules, since both the service provider and the receiver are located in taxable territory, the place of provision would be the location of the service receiver, i.e., New Delhi. On the basis of above and as per the Place of Provision of Services Rules, 2012, which of the following is correct —