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 - goods sold to Associated Enterprises (AEs) - NP Determination - The TPO has not given any reason as to why he did not consider above said two expenses while working out net profit margin of “Domestic-Personal care division”. - it has to be held that the international transactions of making exports to AEs are at arms length and hence no T.P adjustment is called for. - AT
TP Adjustment - goods sold to Associated Enterprises (AEs) - NP Determination - The TPO has not given any reason as to why he did not consider above said two expenses while working out net profit margin of “Domestic-Personal care division”. - it has to be held that the international transactions of making exports to AEs are at arms length and hence no T.P adjustment is called for. - AT
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