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...
Deemed sale - transfer of right to use goods or not - inter-state transfer of goods - the owner of the cylinder is IOCL. The transport/supply does not fall within the ambit of transfer of goods as defined in “sale”. Further, when transaction has taken place in Assam, the respondent authorities cannot have any jurisdiction over Interstate. - HC
Deemed sale - transfer of right to use goods or not - inter-state transfer of goods - the owner of the cylinder is IOCL. The transport/supply does not fall within the ambit of transfer of goods as defined in “sale”. Further, when transaction has taken place in Assam, the respondent authorities cannot have any jurisdiction over Interstate. - HC
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