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...
Proportionate allowability of lease premium u/s 37 - it is difficult to appreciate that fact of rent being depressed rent can only be appreciated as such if there is recital about it in the lease rent - substantial amount of money was paid as premium, claimed and shown by assessee to be advance rents and where rents reserved - no hesitation to infer that rents reserved are depressed rents - deduction allowable
Proportionate allowability of lease premium u/s 37 - it is difficult to appreciate that fact of rent being depressed rent can only be appreciated as such if there is recital about it in the lease rent - substantial amount of money was paid as premium, claimed and shown by assessee to be advance rents and where rents reserved - no hesitation to infer that rents reserved are depressed rents - deduction allowable
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