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...
Transfer Pricing Adjustment - CIT(A) restricted addition - selection of comprables - TPO / A.O. directed to adjust operating cost by excluding abnormal cost incurred on account of start-up company like salary, rent and depreciation. - AT
Transfer Pricing Adjustment - CIT(A) restricted addition - selection of comprables - TPO / A.O. directed to adjust operating cost by excluding abnormal cost incurred on account of start-up company like salary, rent and depreciation. - AT
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