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...
Manufacture - appellants have assembled the kit of bought out items - Chapter 85/87 - the activity of packing of various parts into small retail packing and sale thereof to various customers does not fall under the purview of manufacture. - AT
Manufacture - appellants have assembled the kit of bought out items - Chapter 85/87 - the activity of packing of various parts into small retail packing and sale thereof to various customers does not fall under the purview of manufacture. - AT
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