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 of imported goods - related party transaction - the relationship did not influence the price - Rule 3(3)(a) & 3(3)(b) provide different means of establishing the acceptability of a transaction value - Rule 3(3)(b) cannot be made applicable while deciding the transaction value in the present case
Valuation of imported goods - related party transaction - the relationship did not influence the price - Rule 3(3)(a) & 3(3)(b) provide different means of establishing the acceptability of a transaction value - Rule 3(3)(b) cannot be made applicable while deciding the transaction value in the present case
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