Site where employees are deputed for machine maintenance qualifies as fixed establishment : AAR

In re IZ-Kartex named after P G Korobkov Ltd (GST AAR West Bengal)

It is evident from the above discussion that the MARC Holder maintains suitable structures in terms of human and technical resources at the sites of BCCL. It ensures supervision of the equipment, supply of spares and consumable and overheads for 5000 annual working hours for seventeen years, indicating sufficient degree of permanence to the human and technical resources employed at the sites. The MARC Holder, therefore, supplies the service at the sites from

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