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...
Recording of wrong facts & reasoning by Tribunal - Tribunal did not correctly appreciate as to what AO and CIT (A) held and what was their reasoning which led to their respective conclusion - Tribunal being the last Court of appeal on facts, its finding on the question of fact is of significance - case remanded to tribunal
Recording of wrong facts & reasoning by Tribunal - Tribunal did not correctly appreciate as to what AO and CIT (A) held and what was their reasoning which led to their respective conclusion - Tribunal being the last Court of appeal on facts, its finding on the question of fact is of significance - case remanded to tribunal
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