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...
Transfer pricing adjustment towards notional guarantee commission chargeable for the guarantee extended to its associated enterprises - commission chargeable for guarantee commission by the assessee to its associated enterprises should be taken at 0.5 per cent. as the arm's length price - AT
Transfer pricing adjustment towards notional guarantee commission chargeable for the guarantee extended to its associated enterprises - commission chargeable for guarantee commission by the assessee to its associated enterprises should be taken at 0.5 per cent. as the arm's length price - AT
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