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...
Income from royalty - bookings arising from India, the payment for Altea Reservation System (ARS) is made by the British Airways for the use of system for the purpose of business in India and for the purpose of earning income from India - Mere amendment to Section 9(1)(vi) cannot result in a change. - the Finance Act, 2012 will not affect Article 12 of the DTAAs - AT
Income from royalty - bookings arising from India, the payment for Altea Reservation System (ARS) is made by the British Airways for the use of system for the purpose of business in India and for the purpose of earning income from India - Mere amendment to Section 9(1)(vi) cannot result in a change. - the Finance Act, 2012 will not affect Article 12 of the DTAAs - AT
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