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...
Sales computation - goods under transit - We agree that the accounting policy, using the word ‘coincide’, is not very appropriately worded, but then the same is not to be read strictly, as one would read a provision of law, giving due emphasis to every word, but as conveying broadly the intent, as of transfer of ownership of goods in the present case. - AT
Sales computation - goods under transit - We agree that the accounting policy, using the word ‘coincide’, is not very appropriately worded, but then the same is not to be read strictly, as one would read a provision of law, giving due emphasis to every word, but as conveying broadly the intent, as of transfer of ownership of goods in the present case. - AT
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