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...
"Mark to Market” loss - AO did not disallow the claim of loss but CIT(A) disallowed the claim of loss - In the absence of any fact with regard to the nature of the said transaction, it would not be possible to accept the contention of the revenue with regard to 'Mark to Market' loss. - Claim allowed - HC
"Mark to Market” loss - AO did not disallow the claim of loss but CIT(A) disallowed the claim of loss - In the absence of any fact with regard to the nature of the said transaction, it would not be possible to accept the contention of the revenue with regard to 'Mark to Market' loss. - Claim allowed - HC
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