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...
Validity of remand order passed by the Commissioner (Appeals) - The tribunal found that the Commissioner (Appeals) erred in remanding the case without meeting specific statutory conditions under Section 128A(3)(b) of the Customs Act, 1962. The tribunal set aside the impugned remand order and directed the Commissioner (Appeals) to re-examine and dispose of the matter afresh on merits, emphasizing the importance of adhering to legal provisions in appellate proceedings. - AT
Validity of remand order passed by the Commissioner (Appeals) - The tribunal found that the Commissioner (Appeals) erred in remanding the case without meeting specific statutory conditions under Section 128A(3)(b) of the Customs Act, 1962. The tribunal set aside the impugned remand order and directed the Commissioner (Appeals) to re-examine and dispose of the matter afresh on merits, emphasizing the importance of adhering to legal provisions in appellate proceedings. - AT
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