Subcontracting Isn't Intermediary Service; Impacts CENVAT Credit Refund Eligibility for Export Services Under Tax Rules.

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....Refund of unutilized CENVAT credit - Export of services - intermediary service - place of provision of service - Sub-contracting for a service is also not an intermediary service. The supplier of main service may decide to outsource the supply of main service, either fully or partly, to one or more sub-contractors. Such sub-contractor provides the main supply, either fully or a part thereof and does not merely arrange or facilitate the main supply between the principal supplier and his customers and therefore clearly not an intermediary. - AT....