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...
Royalties and fees for included services - whether the bio-equivalence study is a research activity - applicant having no PE in India, such income would not be taxable in India by virtue of relevant provisions of DTAA between India and Canada - AT
Royalties and fees for included services - whether the bio-equivalence study is a research activity - applicant having no PE in India, such income would not be taxable in India by virtue of relevant provisions of DTAA between India and Canada - AT
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