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...
When the appellant did not avail opportunity to reconcile the figures and guide the authorities below as to which figure shall govern the appellant, there is no necessity to remand the matter for further opportunity. - AT
When the appellant did not avail opportunity to reconcile the figures and guide the authorities below as to which figure shall govern the appellant, there is no necessity to remand the matter for further opportunity. - AT
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