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Questions of law proposed in an appeal from a Tribunal's...
Questions arising from miscellaneous application orders cannot challenge unaltered Tribunal findings, leaving the original order separately challengeable.
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Questions of law proposed in an appeal from a Tribunal's miscellaneous-application order must arise from that order, rather than from an unaltered finding in the original appellate order. Where the miscellaneous order only modified the terms of remand and left intact the finding that an accepted sale-and-purchase software transaction subject to arm's length price determination did not give rise to a dependent agent permanent establishment issue, challenges to that finding fell outside the appeal's scope. The Revenue's appeal was dismissed, while its right to challenge the original Tribunal order in accordance with law remained open.
Questions of law proposed in an appeal from a Tribunal's miscellaneous-application order must arise from that order, rather than from an unaltered finding in the original appellate order. Where the miscellaneous order only modified the terms of remand and left intact the finding that an accepted sale-and-purchase software transaction subject to arm's length price determination did not give rise to a dependent agent permanent establishment issue, challenges to that finding fell outside the appeal's scope. The Revenue's appeal was dismissed, while its right to challenge the original Tribunal order in accordance with law remained open.
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