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...
Admissibility of appeals - grant of ITC - merely because certain documents may have been brought on record may not itself be sufficient to grant ITC - once claim had been rejected by the AO, the appellate authority was obliged to record a positive finding after due appraisal of the evidence on record or calling remand report - failure leads to order erroneous and are premature - remanded
Admissibility of appeals - grant of ITC - merely because certain documents may have been brought on record may not itself be sufficient to grant ITC - once claim had been rejected by the AO, the appellate authority was obliged to record a positive finding after due appraisal of the evidence on record or calling remand report - failure leads to order erroneous and are premature - remanded
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