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27 ST/85229,85230,85231,85232,85613,86387, 86711,87194/2015 5.6 Further, as per the details of the service provided by the appellant's subsidiaries abroad, it is seen that they relate mainly to "Maintenance, Defects and Updates (Installation, Enhancements and Bug fix), Testing (Integration test, system test, end to end test, performance test, regression test, user acceptance test and deploy solution test) and Test coordination". From the nature of the activities, it is obvious that these services cannot be performed from India at all as the service recipient's systems are located abroad. Maintenance, testing, removal of defects, etc. of the systems located abroad has to be done at the site where the systems are located. Thus from the nature of the activities undertaken with respect to onsite services, it is seen that they cannot be performed in or provided from India. The appellant had also referred the matter to the Central Board of Excise and Customs seeking clarification in this regard and the C.B.E. & C. vide letter dated 23-11-2009 had clarified that if the services are rendered partly offsite and partly onsite, then only that operation provided from India (off-shore service) can be treated as export. The C.B.E. & C. clarification was also based on the RBI Circular No. 54, dated 29-6-2002. This clarification issued by the C.B.E. & C. makes the matter abundantly clear that onsite services rendered in respect of IT software services cannot be considered as export for the purposes of claiming export benefits. To a specific query raised by the bench during the course of arguments, it was clarified that while the off-shore services have been certified as export by the competent authorities (softex bills of export certified by the competent authorities), no such certification exists for the on-site services rendered abroad. This also corroborates the fact that on-site services are not exported from India.