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...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Deduction of tax at source u/s. 195 - it is proved that assessee is merely a trader of software products of the foreign company - payment made is not in the nature of 'royalty'. - AT
Deduction of tax at source u/s. 195 - it is proved that assessee is merely a trader of software products of the foreign company - payment made is not in the nature of 'royalty'. - AT
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