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...
Valuation - manufactured goods under-valued - quantification of evasion - nothing has been brought on record by the appellants that the statements have been recorded under duress/coercion. It is not the case of the appellant that the said statements were retracted in reasonable time.
Valuation - manufactured goods under-valued - quantification of evasion - nothing has been brought on record by the appellants that the statements have been recorded under duress/coercion. It is not the case of the appellant that the said statements were retracted in reasonable time.
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