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...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Where a common adjudication order covers multiple noticees, a Bench should not entertain one noticee's appeal on merits merely because that noticee's office falls within its territorial limits. Applying forum non conveniens and its prior decision, the Tribunal said the proper course was to place the matter before the President under Notification No. 1/2022 for constitution of the appropriate Bench to hear all appeals from the same order, avoiding conflicting decisions, ensuring uniformity of fact and law, and keeping the matter under single High Court supervision.
Where a common adjudication order covers multiple noticees, a Bench should not entertain one noticee's appeal on merits merely because that noticee's office falls within its territorial limits. Applying forum non conveniens and its prior decision, the Tribunal said the proper course was to place the matter before the President under Notification No. 1/2022 for constitution of the appropriate Bench to hear all appeals from the same order, avoiding conflicting decisions, ensuring uniformity of fact and law, and keeping the matter under single High Court supervision.
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