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...
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Levy of Service Tax - Intellectual Property Service - permission granted to the CBUs / TMUs to affix the brand name / trade name belonging to them on the IMFL manufactured - The ultimate beneficiary of the technical know-how are the intellectual property if any for that matter is the appellant themselves and therefore, it is incorrect to say that there is any transfer of temporary leasing of intellectual property. Therefore, the entire case of the Department is based on a false surmise. - AT
Levy of Service Tax - Intellectual Property Service - permission granted to the CBUs / TMUs to affix the brand name / trade name belonging to them on the IMFL manufactured - The ultimate beneficiary of the technical know-how are the intellectual property if any for that matter is the appellant themselves and therefore, it is incorrect to say that there is any transfer of temporary leasing of intellectual property. Therefore, the entire case of the Department is based on a false surmise. - AT
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