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 of goods - charges on account of training customer's staff being purely optional has no nexus with the manufacturing and marketing of goods and therefore, not includable in the assessable value - AT
Valuation of goods - charges on account of training customer's staff being purely optional has no nexus with the manufacturing and marketing of goods and therefore, not includable in the assessable value - AT
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