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...
Nature of activity - manufacture or service - making of photo books/albums, calendars, brochures etc. to their different customers - The Tribunal concurred with the assessee's contention that their activity constitutes 'manufacture' rather than a taxable service. They noted that the process undertaken by the assessee involves significant transformation and results in the creation of new commercial products.
Nature of activity - manufacture or service - making of photo books/albums, calendars, brochures etc. to their different customers - The Tribunal concurred with the assessee's contention that their activity constitutes 'manufacture' rather than a taxable service. They noted that the process undertaken by the assessee involves significant transformation and results in the creation of new commercial products.
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