Export eligibility in case of service

ASHUTOSH KUMAR (75 Points)

18 December 2019  
Query
There is a development of marketing content that is required to be done.
- Parties Involved in the Transaction
- Group Company ( Situated in China)
- Holding Company (Situated in China)
- ABC CO. (Located in India)

- Scenario

1. Group company has given order to holding company for developing marketing content for India market.

2. Holding Company approached to ABC Co. to develop the content.

Whether the above transaction qualifies for the "Export of Service" or not ?
If yes then please states the conditions under which we can consider this transaction as an Export of Service??

Note : Developed content will be utilised in Indian market .