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...
Nature of activity - At no stage custody of the coal is taken by the appellant or transportation of the coal, as forwarders, is arranged by the appellant. - the services rendered by the appellant would not qualify as C&F Agent
Nature of activity - At no stage custody of the coal is taken by the appellant or transportation of the coal, as forwarders, is arranged by the appellant. - the services rendered by the appellant would not qualify as C&F Agent
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