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...
Interest - relevant date for calculation of interest - Setting aside an order means there is no order and party relegated for fresh adjudication. Stage of adjudication cannot be said to be determination. An adjudication will culminate in an order and such order would be determination and/or ascertainment of duty, and no interest is payable - HC
Interest - relevant date for calculation of interest - Setting aside an order means there is no order and party relegated for fresh adjudication. Stage of adjudication cannot be said to be determination. An adjudication will culminate in an order and such order would be determination and/or ascertainment of duty, and no interest is payable - HC
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