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 on delayed refund - relevant date - When the refund itself is not matured prior to the date of Appellate Tribunal’s order, there is no question of interest for the period prior to the date of order.
Interest on delayed refund - relevant date - When the refund itself is not matured prior to the date of Appellate Tribunal’s order, there is no question of interest for the period prior to the date of order.
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