The CBIC’s Circular No. 232/26/2024 clarifies the place of supply for data hosting services provided by Indian providers to overseas cloud computing service providers. The circular addresses key issues, confirming that data hosting providers are not considered intermediaries as per the IGST Act. It clarifies that these services are provided on a principal-to-principal basis and are not in relation to goods “made available” by recipients, nor are they directly tied to immovable property. Consequently, the place of supply for such services will be the location of the recipient, i.e., outside India for overseas clients. This means data hosting services qualify as exports, allowing Indian providers to benefit from zero-rated GST. This clarification simplifies compliance, enhances India’s competitive advantage in the IT sector, and supports growth in cloud computing services.