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...
Justification for the expenditure - amount paid towards secondment of employees - The contention of the AO that, real beneficiary of the Australian entity’s employees was not the JV but the AE, rejected. - Revenue is not permitted to hold salary payment reimbursed to AE is a non deductible expenditure.
Justification for the expenditure - amount paid towards secondment of employees - The contention of the AO that, real beneficiary of the Australian entity’s employees was not the JV but the AE, rejected. - Revenue is not permitted to hold salary payment reimbursed to AE is a non deductible expenditure.
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