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...
A limitation objection to a demand raised under the extended limitation period must be decided before the matter proceeds on merits where success on limitation could make remand unnecessary. The notes state that the Tribunal had recorded the contention that the demand was time-barred and that extended limitation was unavailable without suppression of facts, but failed to determine it. The matter was therefore sent back to the Tribunal solely to decide limitation, while the remand on merits was maintained subject to the outcome of that determination.
A limitation objection to a demand raised under the extended limitation period must be decided before the matter proceeds on merits where success on limitation could make remand unnecessary. The notes state that the Tribunal had recorded the contention that the demand was time-barred and that extended limitation was unavailable without suppression of facts, but failed to determine it. The matter was therefore sent back to the Tribunal solely to decide limitation, while the remand on merits was maintained subject to the outcome of that determination.
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