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...
Rejection of refund claim - appellant has not opted for provisional assessment - the refund claim cannot be rejected merely because an assessee had not opted for provisional assessment when there is excess payment of duty - the rejection of refund-claim alleging that the appellant has not opted for provisional assessment is not justified. - AT
Rejection of refund claim - appellant has not opted for provisional assessment - the refund claim cannot be rejected merely because an assessee had not opted for provisional assessment when there is excess payment of duty - the rejection of refund-claim alleging that the appellant has not opted for provisional assessment is not justified. - AT
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