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 - reimbursable expenses - It would not be possible to draw a distinction between the portion of the consideration that does not relate to these activities. In consequence, the tax liability crystallises on the gross value services subject to the various deductions permitted by the first appellate authority - demand with interest upheld.
Valuation - reimbursable expenses - It would not be possible to draw a distinction between the portion of the consideration that does not relate to these activities. In consequence, the tax liability crystallises on the gross value services subject to the various deductions permitted by the first appellate authority - demand with interest upheld.
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