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...
TDS u/s 195 - royalty - purchase of software - copyrighted articles - payments made by it to various suppliers of six countries did not amount to royalty within the definition of Article 12/13(3) of the DTAA and it was not obliged to deduct tax at source - AT
TDS u/s 195 - royalty - purchase of software - copyrighted articles - payments made by it to various suppliers of six countries did not amount to royalty within the definition of Article 12/13(3) of the DTAA and it was not obliged to deduct tax at source - AT
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