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 expenses - inability of the assessee to provide direct evidence to establish that these expenses wholly and exclusively incurred for the purpose of business. - disallowance has been restricted to 20 per cent. without any rhyme and reason - disallowances restricted to 5% only - AT
Disallowance of expenses - inability of the assessee to provide direct evidence to establish that these expenses wholly and exclusively incurred for the purpose of business. - disallowance has been restricted to 20 per cent. without any rhyme and reason - disallowances restricted to 5% only - AT
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