Subcontracted services performed on a supplier's own account,...

Subcontracted services performed on a supplier's own account, wholly or partly, fall outside the intermediary definition in section 2(13) of the IGST Act. Intermediary status requires an agent-like role arranging or facilitating a separate supply between other persons; participation in a wider commercial chain is insufficient. Contractual obligations, authority, actual performance, invoicing and remuneration must be assessed together. Export treatment separately requires an Indian supplier, an overseas recipient, a place of supply outside India, permitted payment and parties who are not merely establishments of a distinct person. Separately incorporated Indian and foreign group companies are separate persons. For the relevant earlier periods, intermediary services had their place of supply at the supplier's location. Zero-rated refund claims remain subject to applicable documentation and other requirements.