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...
TP Adjustment - payment made to its AE towards Maintenance services relating to software licenses - There is merit in the contentions of the assessee that the distribution of software licenses and their maintenance are inter-linked. - TPO was not justified in viewing maintenance services as separate from the distribution activity.
TP Adjustment - payment made to its AE towards Maintenance services relating to software licenses - There is merit in the contentions of the assessee that the distribution of software licenses and their maintenance are inter-linked. - TPO was not justified in viewing maintenance services as separate from the distribution activity.
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