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...
Restoration of name of company on the ROC - failure to file the returns - It being admitted by ROC that the accounting transactions undertaken qua its avowed objective were significant, the business being carried on by the company cannot be termed cosmetic or inconsequential - Tribunal has overlooked the factum of the significant accounting transactions - removal of name from the ROC was not justified
Restoration of name of company on the ROC - failure to file the returns - It being admitted by ROC that the accounting transactions undertaken qua its avowed objective were significant, the business being carried on by the company cannot be termed cosmetic or inconsequential - Tribunal has overlooked the factum of the significant accounting transactions - removal of name from the ROC was not justified
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