Sections extracted
- Section 2(13)
- Section 13(8)(b)
- Section 13(3)(a)
- Section 13(4)
- sections 13(3) to 13(13)
- Section 13(2)
- Section 2(6)
GST circular working note
Circular 232/26/2024-GST: Clarification on place of supply of data hosting services provided by service providers located in India to cloud computing service providers located outside India
Source-led decode of CBIC Circular 232/26/2024-GST with the actual provisions, rules, forms and official PDF trail.
Reviewed by CA Nikhil Gupta · Updated 5 October 2026
Filing identity
Circular number
232/26/2024-GST
Date
2024-09-11
CBIC record
1003231
PDF source
official text PDF; 5 page(s)
Form in 2 minutes
Circular 232/26/2024-GST deals with clarification on place of supply of data hosting services provided by service providers located in India to cloud computing service providers located outside India. Read it as a rate, classification and taxability mapping: identify the supply, supplier, recipient, tariff or service description, notification entry and event date before applying the circular. The circular is binding administrative clarification under the GST framework only to the extent of the issue it answers; the Act, Rules, notifications and event-date version still control the final legal result.
Working point: On the issue of clarification on place of supply of data hosting services provided by service providers located in India to cloud computing service providers located outside India, a practitioner should match the product or service facts to the circular's described entry instead of extending the answer to nearby supplies by label alone.
Bare law, rules and notifications
Rules extracted
No CGST Rule number was expressly extracted from Circular 232/26/2024-GST.
Forms extracted
No GST form was expressly extracted from Circular 232/26/2024-GST.
Notifications and linked circulars
- Circular no. 159/15/2021-GST
The source map above is limited to citations actually extracted from the official Circular 232/26/2024-GST PDF. Where the transaction also touches another charging section, exemption entry, return rule or limitation provision, document that separate source before filing or advising.
Paragraph-wise decode
| Para | Issue dealt with in the circular |
|---|---|
| 2.1 | It has been represented that some field formations are of the view that the place of supply of data hosting services provided by the service providers located in India to cloud computing service providers located outside India is the location of data hosting service provider in India and therefore, the benefit of export of services is not available on such supply of data hosting services. |
| 2.2 | Thus, clarification has been sought in respect of the following issues- (i) Whether data hosting service provider qualifies as ‘Intermediary’ between the cloud computing service provider and their end customers/users/subscribers as per Section 2(13) of the Integrated Goods and Services Tax Act, 2017 (herein after referred to as the “IGST Act”) and whether the services provided by data hosting service provider to cloud... |
| 3.1 | Whether data hosting service provider qualifies as ‘Intermediary’ between the cloud computing service provider and their end customers/users/subscribers as per Section 2(13) of the IGST Act and whether the services provided by data hosting service provider to cloud computing service providers are covered as intermediary services and whether the place of supply of the same is to be determined as per section 13(8)(b) of IGST... |
| 3.1.1 | As per section 2(13) of the IGST Act, read with Circular no. 159/15/2021-GST dated 20.09.2021, a broker, agent or any other person who arranges or facilitates the main supply of goods or services or both or securities and has not involved himself in the main supply on his own account is considered as ‘intermediary’. Persons who supply goods or services, or both on their own account are not covered in the definition of... |
| 3.1.2 | The cloud computing service providers generally enter into contract with data hosting service providers to use their data centres for hosting cloud computing services. Data hosting service provider either owns premises for data centre or operates data centre on leased premises, procures infrastructure and human resource, handles operations like infrastructure monitoring, IT management and equipment maintenance, etc. to... |
Use these paragraph cues to locate the operative part quickly, then read the full official PDF for conditions, exceptions, examples, effective dates and past-period regularisation language.
Workflow
- Identify issue.
Record the taxpayer, supply, return period, order or refund event covered by Circular 232/26/2024-GST. - Map source.
Open the circular PDF with the Act, Rule and notification entries listed above. - Compile proof.
Contract, invoice description, product literature, HSN/SAC support, rate notification, exemption condition and tax-position memo. - Close filing.
Use the portal or officer channel that matches the event date and keep the acknowledgement with the source PDF.
Forms and downloadable source
Circular 232/26/2024-GST does not prescribe a separate static form PDF in its extracted source text. The operative document for this page is the circular PDF and the applicable Act, Rule, notification or portal process.
Do not use a form title by memory alone. Confirm the live portal, the rule that prescribes the form, historical return period and any officer instruction before upload or reply.
Highlighted advisory points
Scope
Circular 232/26/2024-GST should be confined to clarification on place of supply of data hosting services provided by service providers located in India to cloud computing service providers located outside India; nearby issues require their own source check.
Evidence
Keep the official PDF, transaction documents and portal record together so a reviewer can reproduce the conclusion.
Version
For historical periods, use the law and portal version applicable to the event, not merely the current screen label.
Exam and advisory case study
For exams and opinions, write the classification path: facts, statutory entry, notification condition, circular clarification, past-period treatment and practical billing result. For Circular 232/26/2024-GST, a complete answer names the issue, lists the controlling provisions extracted above, applies the circular's operative answer, and then states what the taxpayer or officer must do in the return, refund, appeal, billing or record file.
Finin2min summary and Q&A
Summary: Circular 232/26/2024-GST is a source-specific GST clarification on clarification on place of supply of data hosting services provided by service providers located in India to cloud computing service providers located outside India. Use the exact official PDF, not a generic circular checklist, and preserve the law/rule/notification map with the working file.
Is the circular itself the full law?
No. It clarifies administration under GST. The Act, Rules, notifications, court orders and facts of the transaction remain necessary.
When is a form PDF needed?
Only when the circular or linked rule actually points to a prescribed form. If the page lists forms, use the form compendium and the current GST portal version.
Can this be applied to another tax period?
Only after checking the effective date, amendment history and any past-period regularisation language in the official circular and related notification.
Primary official sources
CBIC circular metadata | Official CBIC PDF viewer | CBIC circular list | GST Council circulars
This Finin2min page is an educational working note. Official legislation, Gazette instruments, circulars, portal rules, court decisions and the facts of the matter prevail. Obtain professional advice for a live filing, refund, appeal or dispute.