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...
Business auxiliary services - various components of the sale value recovered as ‘trade margin’ - the appellant does not, at any stage, become the owner of the goods, there can be no doubt that the said income is not trading profit but is consideration for some specific services rendered by the appellant
Business auxiliary services - various components of the sale value recovered as ‘trade margin’ - the appellant does not, at any stage, become the owner of the goods, there can be no doubt that the said income is not trading profit but is consideration for some specific services rendered by the appellant
Note: It is a system-generated summary and is for quick reference only.