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...
Addendum to show-cause notice after receipt of the reply to show-cause - the learned Commissioner has erred in issuing addendum to show-cause notice after receipt of the reply to show-cause notice dated 18.12.2009. The addendum is also vitiated on the ground that there is no reference in the show-cause notice of any samples being forwarded for test. - AT
Addendum to show-cause notice after receipt of the reply to show-cause - the learned Commissioner has erred in issuing addendum to show-cause notice after receipt of the reply to show-cause notice dated 18.12.2009. The addendum is also vitiated on the ground that there is no reference in the show-cause notice of any samples being forwarded for test. - AT
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