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...
Valuation - Inclusion of reimbursement of expenses - it does not have any evidence as to what was the actual amount of such reimbursements and therefore as the appellant is not in a position to claim such deduction for want of evidence to establish the exact amount of such reimbursements - AT
Valuation - Inclusion of reimbursement of expenses - it does not have any evidence as to what was the actual amount of such reimbursements and therefore as the appellant is not in a position to claim such deduction for want of evidence to establish the exact amount of such reimbursements - AT
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