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...
TP adjustment - comparable selection - functinal dissimilarity - media content and TV broadcasting are totally dissimilar activities - not at all comparable - AO/ TPO to exclude the broadcasting companies from comparables
TP adjustment - comparable selection - functinal dissimilarity - media content and TV broadcasting are totally dissimilar activities - not at all comparable - AO/ TPO to exclude the broadcasting companies from comparables
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