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 on refund - Money wrongly attached - the provision of interest in Section 244-A would have no applicability in the present case because it is a case of illegal attachment and retention - interest 10% for wrongful retention of money for a period of about 15 months, cannot be said to be excessive by any standards - directed to pay interest within two months otherwise further interest @ 9%
Interest on refund - Money wrongly attached - the provision of interest in Section 244-A would have no applicability in the present case because it is a case of illegal attachment and retention - interest 10% for wrongful retention of money for a period of about 15 months, cannot be said to be excessive by any standards - directed to pay interest within two months otherwise further interest @ 9%
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