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...
Since order passed by the Commission is an agreement in a statutory form, the assessee, having been granted immunity from prosecution, cannot challenge the imposition of penalty only - Order of penalty and prosecution cannot be segregated, either the applicant accepts the order in its entirety or the settlement fails - HC
Since order passed by the Commission is an agreement in a statutory form, the assessee, having been granted immunity from prosecution, cannot challenge the imposition of penalty only - Order of penalty and prosecution cannot be segregated, either the applicant accepts the order in its entirety or the settlement fails - HC
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