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...
Validity of demand - order has been passed without proper notice to petitioner - Before passing any order, a personal hearing shall be given to petitioner with atleast seven working days advance notice. After the personal hearing, petitioner, should they wish to file written submissions recording what transpired during the hearing, those written submissions shall be submitted within three days after the personal hearing. The order to be passed shall be a well reasoned order discussing every submission made by petitioner and the order shall give a finding on every submission made by petitioner - HC
Validity of demand - order has been passed without proper notice to petitioner - Before passing any order, a personal hearing shall be given to petitioner with atleast seven working days advance notice. After the personal hearing, petitioner, should they wish to file written submissions recording what transpired during the hearing, those written submissions shall be submitted within three days after the personal hearing. The order to be passed shall be a well reasoned order discussing every submission made by petitioner and the order shall give a finding on every submission made by petitioner - HC
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