Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
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Movement of goods from Maharashtra to Buffer Depots and Satellite Depots in other States was treated as stock transfer, not an inter-State sale, because the Agreement and MOU did not create a binding prior contract fixing quantity, specification or determinative price at dispatch. The concluded sales arose only at depot level on receipt and acceptance of purchase orders, and the goods moved as mixed inventory replenishment under stock transfer documents. Form F declarations for 2008-09 could not be rejected for omitting lorry receipt numbers and vehicle details where the lorry receipts themselves proved dispatch; those omissions were only minor procedural defects.
Movement of goods from Maharashtra to Buffer Depots and Satellite Depots in other States was treated as stock transfer, not an inter-State sale, because the Agreement and MOU did not create a binding prior contract fixing quantity, specification or determinative price at dispatch. The concluded sales arose only at depot level on receipt and acceptance of purchase orders, and the goods moved as mixed inventory replenishment under stock transfer documents. Form F declarations for 2008-09 could not be rejected for omitting lorry receipt numbers and vehicle details where the lorry receipts themselves proved dispatch; those omissions were only minor procedural defects.
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