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d) The Appellant was also engaged in Trading activity of Fabrics and receiving income from sale of fabrics. Copies of invoices of purchase and sale of fabrics are pages 39 to 78 of the Appeal.

3.2. He has submitted that the activities viz. development of e- learning course content and supply of tutors for online tutoring, ST/20314/2022 since the consideration is received in foreign exchange and since the place of provision of service as per Rule 3 of the Place of Provision of Service Rules 2012 (POPS Rules, 2012 for short), is the location of the service recipient, which is USA and UAE, the same constitutes "export of service" under Rule 6A of the Service Tax Rules 1994 and hence no service tax was paid thereon by the Appellant. Regarding demand on implementation of the project Aajevika Skills Development Programme, he has submitted that since the Appellant was project implementation authority on behalf of the State Government under a Centrally Sponsored Scheme, the same was not liable to service tax. Further, since the courses conducted by the Appellant under the said Skill Development program were Modular Employable Skill Courses approved by NCVT, the same were approved Vocational Education Course under Section 65B(11)(ii) and therefore fell under the Negative List under Section 66D(1) of the Finance Act 1994. The Appellant accordingly did not pay service tax in respect thereof. He has also submitted that since the trading activity of sale of fabrics is not a service, question of payment of service tax in respect thereof does not arise. 3.3. Elaborating his argument, he has submitted that it is evident from the Appellant's Invoice on Focus Care Inc, USA and the corresponding Softex Form that the Appellant had exported E-learning Course content and since the consideration for the same was received in foreign exchange and since the place of ST/20314/2022 provision of service as per Rule 3 of the Place of Provision of Service Rules 2012(POPS Rules, 2012 for short), is the location of the service recipient, which is USA, the same constitutes "export of service" under Rule 6A of the Service Tax Rules, 1994 and hence no service tax is payable thereon.