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    <description>The case outcome involved the determination that due to the first issue being decided against the department, it was unnecessary to address the permanent establishment issue. The High Court found no substantial question of law in the appeals, rendering consideration of the permanent establishment question academic. Consequently, the questions of law raised were not addressed, and the appeals were disposed of along with any pending applications. The judgment underscored the importance of a Coordinate Bench order in influencing decision-making, with the observation from a previous order impacting the outcome of the current case.</description>
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      <description>The case outcome involved the determination that due to the first issue being decided against the department, it was unnecessary to address the permanent establishment issue. The High Court found no substantial question of law in the appeals, rendering consideration of the permanent establishment question academic. Consequently, the questions of law raised were not addressed, and the appeals were disposed of along with any pending applications. The judgment underscored the importance of a Coordinate Bench order in influencing decision-making, with the observation from a previous order impacting the outcome of the current case.</description>
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