Receipt of consideration in INR: Whether services can qualify as exports?

Zero rating benefits are available for export of services, but not every service provided to a foreign party qualifies as export.
The definition of “export of services” lays down various conditions, including that payment for the services must be received in convertible foreign exchange.
However, in certain cases, receipt of consideration in INR is considered as receipt of foreign exchange if there is a corresponding reduction in the outflow of foreign exchange.
This principle has been upheld by the courts.
Therefore, it cannot be simply concluded that services will not qualify as exports if the consideration is received/retained in Indian Rupees.
The place of supply of such services must fall outside India to qualify as export.