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 - import of Desk top Board classic series - rejection of transaction value - Tribunal upheld that re-determination of value based on NIDB data available in respect of contemporaneous imports.
Valuation - import of Desk top Board classic series - rejection of transaction value - Tribunal upheld that re-determination of value based on NIDB data available in respect of contemporaneous imports.
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