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...
Import of services - collection charges of the Indian bankers who in turn send the same to the appellant for collection to the foreign bankers - Foreign bank has not charged the appellant directly - Appellant cannot be held as importer of services.
Import of services - collection charges of the Indian bankers who in turn send the same to the appellant for collection to the foreign bankers - Foreign bank has not charged the appellant directly - Appellant cannot be held as importer of services.
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