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...
Refund claim - when invoice showed duty and ex-duty price separately in invoice and on scrap being held non-excisable, refund of duty shown in invoice is not hit by bar of unjust enrichment as contracted price for scrap was inclusive of duty - AT
Refund claim - when invoice showed duty and ex-duty price separately in invoice and on scrap being held non-excisable, refund of duty shown in invoice is not hit by bar of unjust enrichment as contracted price for scrap was inclusive of duty - AT
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