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...
Disallowance of interest paid to the bank as well as to the other parties - Revenue authorities have failed to bring on record any cogent evidence and material to show that the borrowed funds have been utilized for the purposes of investment and were not used for the business purposes - claim allowed - AT
Disallowance of interest paid to the bank as well as to the other parties - Revenue authorities have failed to bring on record any cogent evidence and material to show that the borrowed funds have been utilized for the purposes of investment and were not used for the business purposes - claim allowed - AT
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