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...
Withholding of tax u/s 195 - fee for technical services (FTS) - the protocol itself makes it clear that the said ‘MFN’ clause “shall apply” in India-Sweden DTAA. - Issuance of a notification has nowhere been stipulated as a condition precedent therein.
Withholding of tax u/s 195 - fee for technical services (FTS) - the protocol itself makes it clear that the said ‘MFN’ clause “shall apply” in India-Sweden DTAA. - Issuance of a notification has nowhere been stipulated as a condition precedent therein.
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