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...
Taxability - principles of mutuality - services provided to group / promoter companies - The only basis for providing of services by the appellant is on cost sharing basis as per the norms or formula laid down by the members of the appellant company. Therefore, SCN is not maintainable both on the principle of mutuality and on the fact of lack of consideration for such services alleged to have been rendered - AT
Taxability - principles of mutuality - services provided to group / promoter companies - The only basis for providing of services by the appellant is on cost sharing basis as per the norms or formula laid down by the members of the appellant company. Therefore, SCN is not maintainable both on the principle of mutuality and on the fact of lack of consideration for such services alleged to have been rendered - AT
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