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...
Failure to make the necessary disclosures regarding creation/invocation/release of certain pledge transactions and off-market transactions/purchase of shares in the company - whenever the pledging of the shares of the appellants were invoked, the appellants were required to make the necessary disclosures as it involved a change in the shareholding. - AT
Failure to make the necessary disclosures regarding creation/invocation/release of certain pledge transactions and off-market transactions/purchase of shares in the company - whenever the pledging of the shares of the appellants were invoked, the appellants were required to make the necessary disclosures as it involved a change in the shareholding. - AT
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