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 of imported goods - contemporaneous imports - The tribunal observed that the Revenue had not provided adequate evidence or a proper comparison with contemporaneous imports to justify the revaluation of the imported goods' declared value. The lack of such comparison and evidence in revaluation matters was a key factor in the tribunal's decision to set aside the impugned order and allow the appellant's appeal. - AT
Valuation of imported goods - contemporaneous imports - The tribunal observed that the Revenue had not provided adequate evidence or a proper comparison with contemporaneous imports to justify the revaluation of the imported goods' declared value. The lack of such comparison and evidence in revaluation matters was a key factor in the tribunal's decision to set aside the impugned order and allow the appellant's appeal. - AT
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