Why are place of supply provisions different in respect of goods and services?

Goods being tangible do not pose any significant
problems for determination of their place of consumption.
Services being intangible pose problems w.r.t determination
of place of supply mainly due to following factors:
(i) The manner of delivery of service could be altered
easily. For example telecom service could change
from mostly post-paid to mostly pre-paid; billing
address could be changed, billers address could
be changed, repair or maintenance of software
could be changed from onsite to online; banking
services were earlier required customer to go to
the bank, now the customer could avail service
from anywhere;
(ii) Service provider, service receiver and the service
provided may not be ascertainable or may easily
be suppressed as nothing tangible moves and
there would hardly be a trail;
(iii) For supplying a service, a fixed location of
service provider is not mandatory and even
the service recipient may receive service while
on the move. The location of billing could be
changed overnight;
(iv) Sometime the same element may flow to more
than one location, for example, construction
or other services in respect of a railway line, a
national highway or a bridge on a river which
originate in one state and end in the other
state. Similarly a copy right for distribution and
exhibition of film could be assigned for many
states in single transaction or an advertisement
or a programme is broadcasted across the
country at the same time. An airline may issue
seasonal tickets, containing say 10 leafs which
could be used for travel between any two
location in the country. The card issued by Delhi
metro could be used by a person located in
Noida, or Delhi or Faridabad, without the Delhi
metro being able to distinguish the location or
journeys at the time of receipt of payment;
(v) Services are continuously evolving and would
thus continue to pose newer challenges. For
example 15-20 years back no one could have
thought of DTH, online information, online
banking, online booking of tickets, internet,
mobile telecommunication etc.