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...
Valuation - pure agent - reimbursement of expenditure - prima-facie not in agreement with the contention of the Revenue that the sovereign authority in other countries are rendering service to the appellant. - stay granted. - AT
Valuation - pure agent - reimbursement of expenditure - prima-facie not in agreement with the contention of the Revenue that the sovereign authority in other countries are rendering service to the appellant. - stay granted. - AT
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