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...
Levy of Interest - carry forward of excess credit - In the present case, the Appellant reversed the credit in September 2009 but since failed to discharge the interest of the same, consequently, within a period of one year, the interest was demanded from the Appellant by issuing a notice to the Appellant. Hence, the demand for interest is not barred by limitation. - AT
Levy of Interest - carry forward of excess credit - In the present case, the Appellant reversed the credit in September 2009 but since failed to discharge the interest of the same, consequently, within a period of one year, the interest was demanded from the Appellant by issuing a notice to the Appellant. Hence, the demand for interest is not barred by limitation. - AT
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