In reply to the questions raised by the Appellant before AAAR, The Appellate Authority for Advance Ruling  held as under:

1. The service supplied by the Respondent under the Service Agreement dated 1 March 2013 constitute a mixed supply of services falling under the Heading “ accounting services” having SAC 9982,  and under the Heading “other professional, technical and business services” having the SAC 9983. 

2. The service supplied by the Respondent under the Marketing Services Agreement dated 1 December 2012 constitute a mixed supply of Services falling under the Heading “Research and Development services” having SAC 9981, under the   Heading “Other professional, technical and business services” bearing SAC 9983, and under the Heading “other miscellaneous services” bearing SAC 9997. 3.We cannot pass any ruling in relation to the export of services, as the same would require the determination of the place of supply of services, which is not under the jurisdiction and scope of the Advance Ruling Authority.