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...
Valuation - Related party transaction - Revenue appears to have made out a prima facie case for rejecting the declared value on the ground that such value was substantially influenced by direct and indirect flow-backs between the importer and the supplier being related Sun entities. - AT
Valuation - Related party transaction - Revenue appears to have made out a prima facie case for rejecting the declared value on the ground that such value was substantially influenced by direct and indirect flow-backs between the importer and the supplier being related Sun entities. - AT
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