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...
Classification - - vehicle was hired out to third person for the purpose of his journey - There was no tour actually conducted by the appellant in the present case. Neither the appellant adduced evidence in that regard nor also any of the circumstantial evidence could demonstrate in its favour to treat the appellant as a tour operator. - appellant’s claim fails on the plea of classification as tour operator - AT
Classification - - vehicle was hired out to third person for the purpose of his journey - There was no tour actually conducted by the appellant in the present case. Neither the appellant adduced evidence in that regard nor also any of the circumstantial evidence could demonstrate in its favour to treat the appellant as a tour operator. - appellant’s claim fails on the plea of classification as tour operator - AT
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