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...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
When the value of an enterprise is fixed based on the present value of its future earnings there is no scope for any further allowance for any perceived risk factor - Discounted cash flow method was appropriate to determine the arm's length price of the international transaction - AT
When the value of an enterprise is fixed based on the present value of its future earnings there is no scope for any further allowance for any perceived risk factor - Discounted cash flow method was appropriate to determine the arm's length price of the international transaction - AT
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