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 CENVAT credit - either of the two units could have availed the entire credit. As such, it is of the view that denial of credit to the Bangalore unit is not justified. - AT
Denial of CENVAT credit - either of the two units could have availed the entire credit. As such, it is of the view that denial of credit to the Bangalore unit is not justified. - AT
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