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 (T.P) adjustments - notional interest on receivables from Associated Enterprises (A.E) - the credit period extend by the assessee to its AE is very longer period, sometime it is more than one year the contention of assessee that there can be no separate transfer pricing adjustments towards notional interest on outstanding receivables rejected - AT
Transfer Pricing (T.P) adjustments - notional interest on receivables from Associated Enterprises (A.E) - the credit period extend by the assessee to its AE is very longer period, sometime it is more than one year the contention of assessee that there can be no separate transfer pricing adjustments towards notional interest on outstanding receivables rejected - AT
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