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...
Denial of refund claim - there is no dispute that the entire amount as tax liability has been paid by respondent and having been appropriated by the lower authorities in order in original now department cannot turn around and say, There is no payment of amount in the absence of documents - AT
Denial of refund claim - there is no dispute that the entire amount as tax liability has been paid by respondent and having been appropriated by the lower authorities in order in original now department cannot turn around and say, There is no payment of amount in the absence of documents - AT
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