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...
Confiscation of improperly imported goods - Chinese mobile phones – Customs duty cannot be demanded from appellant as it is case of town seizure and date/time of inspection is not known to determine rate of duty, exchange rate and value of goods - Appellant being transporter cannot be expected to know all - he was not aware of smuggled nature of seized goods - No penalty - AT
Confiscation of improperly imported goods - Chinese mobile phones – Customs duty cannot be demanded from appellant as it is case of town seizure and date/time of inspection is not known to determine rate of duty, exchange rate and value of goods - Appellant being transporter cannot be expected to know all - he was not aware of smuggled nature of seized goods - No penalty - AT
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