Place of supply of data hosting services: recipient-location rule makes overseas recipients' location determine export treatment. Data hosting providers in India supply comprehensive data-centre services on their own account-owning or managing premises, hardware, software, power, connectivity, security and personnel-and thus are not intermediaries, their services are not in respect of goods 'made available' by recipients, nor are they services directly related to immovable property. Consequently, the specific place-of-supply rules for intermediaries, goods made available, and immovable property do not apply; the default recipient-location rule governs, making the place of supply the location of the overseas cloud provider and permitting export-of-services treatment if other export conditions are satisfied.