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...
Unaccounted cash credit - peak credit theory - additions were made purely based on facts, unless the facts were duly verified by the AO, the addition should not have been deleted. - AT
Unaccounted cash credit - peak credit theory - additions were made purely based on facts, unless the facts were duly verified by the AO, the addition should not have been deleted. - AT
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