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...
Validity of reassessment proceedings - validity of reasons to believe - Mere repetition of the language of the section is not sufficient. It has to be proved as to how and which material facts were not disclosed.
Validity of reassessment proceedings - validity of reasons to believe - Mere repetition of the language of the section is not sufficient. It has to be proved as to how and which material facts were not disclosed.
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