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...
Valuation of imported goods - While invoking Rule 5, no values of contemporaneous imports were taken for comparison; arbitrarily 30% has been loaded without any authority of law under Rule 5 and clearly the OIO transgressed the scope of remand. - No demand can be made.
Valuation of imported goods - While invoking Rule 5, no values of contemporaneous imports were taken for comparison; arbitrarily 30% has been loaded without any authority of law under Rule 5 and clearly the OIO transgressed the scope of remand. - No demand can be made.
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