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...
DFIA benefits - validity of transfer of DFIA issued under SION E-5 (Biscuits) - There is no actual user condition in existence prior to the issue of PN 84 - There is no merits in the arguement of revenue that the amendments in the DFIA licenses have been obtained through fraudulent means and suppression of facts before the licensing authorities. - AT
DFIA benefits - validity of transfer of DFIA issued under SION E-5 (Biscuits) - There is no actual user condition in existence prior to the issue of PN 84 - There is no merits in the arguement of revenue that the amendments in the DFIA licenses have been obtained through fraudulent means and suppression of facts before the licensing authorities. - AT
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