Intermediary-service classification turns on whether a supplier...

Intermediary-service classification turns on whether a supplier arranges or facilitates an identifiable main supply between other parties; a subcontractor supplying contracted services on its own account is excluded. Marketing, promotion, business-support and IT-enabled services provided independently on a principal-to-principal basis, without authority to bind the foreign principal or participate in third-party arrangements, qualify as export of services rather than intermediary services, supporting refund of unutilised input tax credit. Section 107(11) bars the first appellate authority from effectively remanding a refund matter after annulling the original order, while preserving the Tribunal's separate remand power.