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...
Indexed cost of improvement claimed on flats received under a joint development arrangement requires evidence of actual improvement works and related payments. Construction costs were contractually borne by the developer, and the flats were sold in the semi-furnished condition received from the developer. Quotations and estimates for proposed additional work did not establish material purchases, labour payments, or execution of improvements. The NALA component was also unsupported. Consequently, the claimed indexed cost of improvement was disallowed, and the appeal was dismissed.
Indexed cost of improvement claimed on flats received under a joint development arrangement requires evidence of actual improvement works and related payments. Construction costs were contractually borne by the developer, and the flats were sold in the semi-furnished condition received from the developer. Quotations and estimates for proposed additional work did not establish material purchases, labour payments, or execution of improvements. The NALA component was also unsupported. Consequently, the claimed indexed cost of improvement was disallowed, and the appeal was dismissed.
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