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...
TPA - recovery of expenses - it is pure reimbursement of expenses incurred and no service element is involved - AO/TPO is directed to treat the transaction to be at ALP and adjustment to be made at Rs. Nil.
TPA - recovery of expenses - it is pure reimbursement of expenses incurred and no service element is involved - AO/TPO is directed to treat the transaction to be at ALP and adjustment to be made at Rs. Nil.
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