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...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
Executive Assistants are not entitled to inter-Commissionerate transfer where each Cadre Controlling Authority maintains a separate cadre and the applicable Recruitment Rules provide no absorption by transfer into another Commissionerate. The transfer policy therefore applies to this cadre, and appointment in the transferee Commissionerate cannot be secured through inter-Commissionerate transfer. Transfers treated as deemed loan arrangements may consequently result in repatriation. A request for relaxation on medical grounds may be made by representation for consideration on its merits.
Executive Assistants are not entitled to inter-Commissionerate transfer where each Cadre Controlling Authority maintains a separate cadre and the applicable Recruitment Rules provide no absorption by transfer into another Commissionerate. The transfer policy therefore applies to this cadre, and appointment in the transferee Commissionerate cannot be secured through inter-Commissionerate transfer. Transfers treated as deemed loan arrangements may consequently result in repatriation. A request for relaxation on medical grounds may be made by representation for consideration on its merits.
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