Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Royalty receipt - receipt from uplinking services - The customers are not granted the use of or the right to use any process by the assessee during the course of providing various satellite-based telecommunication services which means that the customers are merely availing a service from the assessee and are not bearing any risk with respect to exploitation of the assessee’s equipment involved in the provision of such service. - the amount received by the assessee from its customers in India as consideration for the provision of a service cannot be characterized as royalty for the use or right to use of a process. - AT
Royalty receipt - receipt from uplinking services - The customers are not granted the use of or the right to use any process by the assessee during the course of providing various satellite-based telecommunication services which means that the customers are merely availing a service from the assessee and are not bearing any risk with respect to exploitation of the assessee’s equipment involved in the provision of such service. - the amount received by the assessee from its customers in India as consideration for the provision of a service cannot be characterized as royalty for the use or right to use of a process. - AT
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