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...
Smuggling - Gold - The onus lies on the Revenue to prove that the goods in question are of smuggled in nature, which the Revenue has failed to discharge their onus with proper evidence. In the impugned order, it is held on the basis of assumption & presumption that the gold is of smuggled in nature which cannot be appreciated. - AT
Smuggling - Gold - The onus lies on the Revenue to prove that the goods in question are of smuggled in nature, which the Revenue has failed to discharge their onus with proper evidence. In the impugned order, it is held on the basis of assumption & presumption that the gold is of smuggled in nature which cannot be appreciated. - AT
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