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...
Tax avoidance, Tax evasion or Tax planning - when there are material evidences to substantiate that the shares were issued to foreign investors, and the conversion of the share was in accordance with the terms of issue of the preference shares appropriately justified with the fair valuation, there is no case treating such an issue/conversion as a means of tax avoidance.
Tax avoidance, Tax evasion or Tax planning - when there are material evidences to substantiate that the shares were issued to foreign investors, and the conversion of the share was in accordance with the terms of issue of the preference shares appropriately justified with the fair valuation, there is no case treating such an issue/conversion as a means of tax avoidance.
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