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...
Jurisdiction of DCIT - not only DCIT had the necessary jurisdiction to do an assessment on the assessee, but assessee by virtue of not objecting to such jurisdiction before the DCIT during the course of assessment cannot now turn back and say that the said officer was not having the necessary jurisdiction to assess it - AT
Jurisdiction of DCIT - not only DCIT had the necessary jurisdiction to do an assessment on the assessee, but assessee by virtue of not objecting to such jurisdiction before the DCIT during the course of assessment cannot now turn back and say that the said officer was not having the necessary jurisdiction to assess it - AT
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