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...
Provision for non-moving inventory - Consistent treatment given by the assessee from year to year with regard to treatment of provision for non-moving inventory in the return of income - Disallowance deleted - AT
Provision for non-moving inventory - Consistent treatment given by the assessee from year to year with regard to treatment of provision for non-moving inventory in the return of income - Disallowance deleted - AT
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