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 final assessment order that ignored the partial relief granted by the DRP and repeated the draft additions was invalid because the assessment had to be passed in conformity with the DRP directions. The Tribunal treated the non-compliance as a violation of the statutory mandate and, following binding precedent, quashed the order; the remaining grounds were therefore academic.
A final assessment order that ignored the partial relief granted by the DRP and repeated the draft additions was invalid because the assessment had to be passed in conformity with the DRP directions. The Tribunal treated the non-compliance as a violation of the statutory mandate and, following binding precedent, quashed the order; the remaining grounds were therefore academic.
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