Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
A GST refund deficiency memo in Form RFD-03 must identify the precise document defects; a vague statement that supporting papers are incomplete is insufficient because the applicant cannot effectively cure unspecified deficiencies. The memo cannot be used to reject the refund claim without particulars, and if treated as a rejection, that reasoning remains unsustainable. The proper course is to communicate the specific defects, allow rectification within time, and then decide the refund claim afresh by a speaking order.
A GST refund deficiency memo in Form RFD-03 must identify the precise document defects; a vague statement that supporting papers are incomplete is insufficient because the applicant cannot effectively cure unspecified deficiencies. The memo cannot be used to reject the refund claim without particulars, and if treated as a rejection, that reasoning remains unsustainable. The proper course is to communicate the specific defects, allow rectification within time, and then decide the refund claim afresh by a speaking order.
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