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...
Penalty imposed u/s 271G - failure to furnish the information/documents required u/s 92D(1) r/w rule 10D - when the TPO has accepted the benchmarking of the assessee, the imposition of penalty under section 271G of the Act is unsustainable
Penalty imposed u/s 271G - failure to furnish the information/documents required u/s 92D(1) r/w rule 10D - when the TPO has accepted the benchmarking of the assessee, the imposition of penalty under section 271G of the Act is unsustainable
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