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...
Refund claim - Period of limitation - claim was filed on 29.07.2004 which was returned on the ground of pre-mature inasmuch as investigation about the valuation work was still going on, accordingly, appellant resubmitted their claim on 28.10.2005 - refund allowed - Provision of unjust enrichment not applicable where the amount is deposited during the investigation - AT
Refund claim - Period of limitation - claim was filed on 29.07.2004 which was returned on the ground of pre-mature inasmuch as investigation about the valuation work was still going on, accordingly, appellant resubmitted their claim on 28.10.2005 - refund allowed - Provision of unjust enrichment not applicable where the amount is deposited during the investigation - AT
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