Intermediary classification determines whether ITeS supplies qualify as export of services and affect export benefit eligibility. Clarifies that a provider of ITeS services who supplies services on its own account is not an intermediary, while a provider whose role is limited to arranging or facilitating another's supply will be an intermediary; mixed cases require fact specific determination of the principal supply. Suppliers not being intermediaries may qualify for export of services benefits if they meet the conditions regarding supplier and recipient locations, place of supply, receipt of payment in convertible foreign exchange, and absence of mere establishment relationships.
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Provisions expressly mentioned in the judgment/order text.
Intermediary classification determines whether ITeS supplies qualify as export of services and affect export benefit eligibility.
Clarifies that a provider of ITeS services who supplies services on its own account is not an intermediary, while a provider whose role is limited to arranging or facilitating another's supply will be an intermediary; mixed cases require fact specific determination of the principal supply. Suppliers not being intermediaries may qualify for export of services benefits if they meet the conditions regarding supplier and recipient locations, place of supply, receipt of payment in convertible foreign exchange, and absence of mere establishment relationships.
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