Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Binding interim judicial directions on tax deduction for leave travel concession payments involving foreign travel are described as prevailing over the employer's statutory withholding obligation during their operation. Although a later Supreme Court ruling clarified that leave travel concession with a foreign leg was not exempt, the notes state that this ruling could not retrospectively impose default liability on an employer that complied with the interim directions. The employer was therefore not treated as an assessee in default, and consequential interest did not survive; demands for tax and interest were deleted.
Binding interim judicial directions on tax deduction for leave travel concession payments involving foreign travel are described as prevailing over the employer's statutory withholding obligation during their operation. Although a later Supreme Court ruling clarified that leave travel concession with a foreign leg was not exempt, the notes state that this ruling could not retrospectively impose default liability on an employer that complied with the interim directions. The employer was therefore not treated as an assessee in default, and consequential interest did not survive; demands for tax and interest were deleted.
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