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...
Addition regarding Cash deposit in Bank Account - based on AIR Information - when there is no evidence with the Revenue that the withdrawals made by the assessee systematically from the bank account have been utilized for some other purpose other than for the unaccounted business of the assessee then the assessee should be given the benefit of peak credit theory and only the peak credit has to be sustained
Addition regarding Cash deposit in Bank Account - based on AIR Information - when there is no evidence with the Revenue that the withdrawals made by the assessee systematically from the bank account have been utilized for some other purpose other than for the unaccounted business of the assessee then the assessee should be given the benefit of peak credit theory and only the peak credit has to be sustained
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