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...
Principle of Res-Judicata - While dismissing appeal of Revenue in first ground of litigation, no doubt Supreme court had left question of law open - However, that could not be ground to reopen case of Revenue - SC
Principle of Res-Judicata - While dismissing appeal of Revenue in first ground of litigation, no doubt Supreme court had left question of law open - However, that could not be ground to reopen case of Revenue - SC
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