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...
Disallowance of deprecation on Goodwill - assessee had entered into an Asset Purchase Agreement (“APA”) to acquire the Global Travel Service Centre (“GTSC”) as a going concern for lump sum consideration ( slump sale basis) - claim of the assessee allowed - AT
Disallowance of deprecation on Goodwill - assessee had entered into an Asset Purchase Agreement (“APA”) to acquire the Global Travel Service Centre (“GTSC”) as a going concern for lump sum consideration ( slump sale basis) - claim of the assessee allowed - AT
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