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 of service - Addition of price of electricity - cannot be considered as part of the gross amount charged for the service of operation of the plant - AT
Valuation of service - Addition of price of electricity - cannot be considered as part of the gross amount charged for the service of operation of the plant - AT
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