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...
Valuation - related parties - technical knowhow fee is for design, drawing and technical information provided to appellant by overseas supplier for setting up of "Instant Coffee" plant which is purely a post-importation activity - value cannot be enhanced - AT
Valuation - related parties - technical knowhow fee is for design, drawing and technical information provided to appellant by overseas supplier for setting up of "Instant Coffee" plant which is purely a post-importation activity - value cannot be enhanced - AT
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