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...
Invocation of extended period of limitation - Extended period is applicable in the present appeal even if waiver from Section 78 penalty has been extended to the appellant under Section 80 of the Finance Act, 1994. - AT
Invocation of extended period of limitation - Extended period is applicable in the present appeal even if waiver from Section 78 penalty has been extended to the appellant under Section 80 of the Finance Act, 1994. - AT
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