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...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Representative/liaison office (LO) - Doctrine of Mutuality - Applicant works on the principle of mutuality and is not an enterprise set up for the purpose of doing business or earning profit - The question of any PE coming into existence does not arise - AAR
Representative/liaison office (LO) - Doctrine of Mutuality - Applicant works on the principle of mutuality and is not an enterprise set up for the purpose of doing business or earning profit - The question of any PE coming into existence does not arise - AAR
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