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...
In the absence of element of mens area, the appellant's conduct cannot be construed to fall within the five elements as required for invoking the extended time proviso - the charges of willful suppression or mis-statement of facts cannot be invoked
In the absence of element of mens area, the appellant's conduct cannot be construed to fall within the five elements as required for invoking the extended time proviso - the charges of willful suppression or mis-statement of facts cannot be invoked
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