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...
Refund claim - Business Auxiliary Services - Export of services - Products support services shall include phone, e-mail, web based and onsite support for all MSFT products. It cannot be said that services have been used in India - AT
Refund claim - Business Auxiliary Services - Export of services - Products support services shall include phone, e-mail, web based and onsite support for all MSFT products. It cannot be said that services have been used in India - AT
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