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...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
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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