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...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
TP Adjustment - share application money remained parked with AE - nothing on record to prove that transaction was sham - TPO could not have treated such transaction as a loan and charged interest thereon on notional basis.
TP Adjustment - share application money remained parked with AE - nothing on record to prove that transaction was sham - TPO could not have treated such transaction as a loan and charged interest thereon on notional basis.
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