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...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Permanent Establishment (‘PE’) in India - income accrued in India - the profits of the PE should be determined on the basis of what an independent enterprise under similar circumstances might be expected to derive on its own- AT
Permanent Establishment (‘PE’) in India - income accrued in India - the profits of the PE should be determined on the basis of what an independent enterprise under similar circumstances might be expected to derive on its own- AT
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