Suppose you have two realms. Realm A and Realm B. Realm A is a universe much like ours, while Realm B is a transcendental place that has pretty much all of the properties we'd expect of something that fits the bill for "qualitative superiority." That is to say: Realm A is described as infinitely less than Realm B. To Realm B and its inhabitants, Realm A is literally a fiction, an illusion, something completely impotent, and nothing happening in Realm A can ever be of any consequence to Realm B because of this.
However, there's a catch: For all their infinite superiority over Realm A, the beings of Realm B can't really interact with it in any way. They can interact with each other, but not with lower realms or beings.
To me, Realm B would be Tier 1, without question. To you, though, it seems like Realm B wouldn't be able to be compared to Realm A because of its lack of ability to interact with it. Ergo, it seems that "superiority" to you hinges on the amount of control that the higher thing is able to exert over the lower. While, in my eyes, that doesn't matter in the slightest.