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...
Retrospective amendment of the Foreign Trade Policy cannot deprive exporters or service providers of SEIS benefits accrued while an operative scheme covered their eligible services. The power to formulate or amend the policy does not authorise retrospective withdrawal of such accrued rights. Services rendered and foreign exchange earned during FY 2019-20 remained eligible despite later notifications introducing Appendix 3X and excluding specified services under Appendix 3E. The notifications operate prospectively from their respective issue dates, requiring processing of accrued SEIS claims and consequential benefits, including claims that could not previously be filed.
Retrospective amendment of the Foreign Trade Policy cannot deprive exporters or service providers of SEIS benefits accrued while an operative scheme covered their eligible services. The power to formulate or amend the policy does not authorise retrospective withdrawal of such accrued rights. Services rendered and foreign exchange earned during FY 2019-20 remained eligible despite later notifications introducing Appendix 3X and excluding specified services under Appendix 3E. The notifications operate prospectively from their respective issue dates, requiring processing of accrued SEIS claims and consequential benefits, including claims that could not previously be filed.
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