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...
Profit sharing agreement - Diversion of income by overriding title or mere application of income - the assessee has been obligated by virtue of the agreement to divert the income at source and also for the contributions made by the holding company - the revenue sharing agreement entered with the holding company by the assessee is diversion of income by overriding title. - Additions deleted.
Profit sharing agreement - Diversion of income by overriding title or mere application of income - the assessee has been obligated by virtue of the agreement to divert the income at source and also for the contributions made by the holding company - the revenue sharing agreement entered with the holding company by the assessee is diversion of income by overriding title. - Additions deleted.
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