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...
Revenue Appeal against one order of Commissioner Appeal whereas Commission has decided two cases simultaneously on similar issues - Though res judicata may not strictly apply to the orders passed by the Commissioner (Appeals), but the aid of such principles can be taken. In the present case if this appeal is allowed, two inconsistent orders will come into existence. The present appeal, therefore, is liable to be dismissed for this reason.
Revenue Appeal against one order of Commissioner Appeal whereas Commission has decided two cases simultaneously on similar issues - Though res judicata may not strictly apply to the orders passed by the Commissioner (Appeals), but the aid of such principles can be taken. In the present case if this appeal is allowed, two inconsistent orders will come into existence. The present appeal, therefore, is liable to be dismissed for this reason.
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