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...
Intellectual Property Rights Service - Reverse Charge Mechanism - payment made to Fosters Australia towards permanent transfer of Fosters trademark and brand under the Deed of Assignment - transfer of right to use - The assignment of trademark and the IPR amounts to permanent transfer and no service tax is applicable on permanent transfer of IP Rights by Foster’s to the appellant. - AT
Intellectual Property Rights Service - Reverse Charge Mechanism - payment made to Fosters Australia towards permanent transfer of Fosters trademark and brand under the Deed of Assignment - transfer of right to use - The assignment of trademark and the IPR amounts to permanent transfer and no service tax is applicable on permanent transfer of IP Rights by Foster’s to the appellant. - AT
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