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...
Imposition of penalty - non-filing of Annual Return containing details of inputs for the period 2004-05 - other than the non-filing of return, no other allegation has been made against the appellant. The returns stand filed thereafter. - No penalty - AT
Imposition of penalty - non-filing of Annual Return containing details of inputs for the period 2004-05 - other than the non-filing of return, no other allegation has been made against the appellant. The returns stand filed thereafter. - No penalty - AT
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