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...
Interest earned on short term deposits - capital receipt OR Income from Other Sources - two Authorities below and the Tribunal, proceeded on the legal principle without making an in-depth study on the facts - the settled legal principle is that the law has to be applied to the facts of the given case and not in the reverse - remanded to AO to record his finding on facts
Interest earned on short term deposits - capital receipt OR Income from Other Sources - two Authorities below and the Tribunal, proceeded on the legal principle without making an in-depth study on the facts - the settled legal principle is that the law has to be applied to the facts of the given case and not in the reverse - remanded to AO to record his finding on facts
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