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...
Accrual of income in India - TP Adjustment - when the amount remunerated by the assessee is found to be satisfying the ‘arms length’ principle, therefore, no further profits could be attributed to the assessee in India even if it was to be held that the latter had a PE in India
Accrual of income in India - TP Adjustment - when the amount remunerated by the assessee is found to be satisfying the ‘arms length’ principle, therefore, no further profits could be attributed to the assessee in India even if it was to be held that the latter had a PE in India
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