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...
Deemed dividend u/s 2(22)(e) - payments ‘made to any concern in which the shareholder is a member’ - common shareholder having a substantial interest in the assessee company as well as in the creditor companies - Revenue failed to prove that the case is falling under the second limb of section 2(22)(e).
Deemed dividend u/s 2(22)(e) - payments ‘made to any concern in which the shareholder is a member’ - common shareholder having a substantial interest in the assessee company as well as in the creditor companies - Revenue failed to prove that the case is falling under the second limb of section 2(22)(e).
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