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...
Duty drawback u/s 74 of CA - filing the refund claim under wrong provisions does not disentitle the legitimate claim of the appellant. Substantive right of the appellant to file their claim under the correct provisions of the Act cannot be denied, therefore, the benefit of Section 14 of the Limitation Act, 1963 is available to the appellant. - AT
Duty drawback u/s 74 of CA - filing the refund claim under wrong provisions does not disentitle the legitimate claim of the appellant. Substantive right of the appellant to file their claim under the correct provisions of the Act cannot be denied, therefore, the benefit of Section 14 of the Limitation Act, 1963 is available to the appellant. - AT
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