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...
Job-work - benefit of N/N. 214/96 and N/N. 84/95-CE cannot be extended to the appellant as the requisite undertakings have not been given by the appellant - These undertakings are not merely procedural undertaking but substantive undertaking in so far as by virtue of this undertaking, the principal manufacturer takes the responsibility of duty liability in case it arose - AT
Job-work - benefit of N/N. 214/96 and N/N. 84/95-CE cannot be extended to the appellant as the requisite undertakings have not been given by the appellant - These undertakings are not merely procedural undertaking but substantive undertaking in so far as by virtue of this undertaking, the principal manufacturer takes the responsibility of duty liability in case it arose - AT
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