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...
Circular Resolutions - not duly circulated to all the Directors - This Tribunal, keeping in mind of the divergent contentions, raised on either side and taking note of the facts and circumstances of the case, in a conspectus fashion, without any haziness, holds that the Circular Resolutions No. 1 to 6 dated 03.11.2020, are Void in Law. - AT
Circular Resolutions - not duly circulated to all the Directors - This Tribunal, keeping in mind of the divergent contentions, raised on either side and taking note of the facts and circumstances of the case, in a conspectus fashion, without any haziness, holds that the Circular Resolutions No. 1 to 6 dated 03.11.2020, are Void in Law. - AT
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