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...
Valuation - 'apple juice concentrate' - documentary evidence of contemporaneous import not furnished - there is a gross contravention of the principles of natural justice, as the appellant were denied access to the document of contemporaneous import - AT
Valuation - 'apple juice concentrate' - documentary evidence of contemporaneous import not furnished - there is a gross contravention of the principles of natural justice, as the appellant were denied access to the document of contemporaneous import - AT
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