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...
Refund claim - provisional assessment not opted - It is settled that even though the assessee has not opted for provisional assessment but the duty was paid in excess admittedly the assessee’s claim of refund within stipulated time of one year, the refund is admissible. The refund cannot be rejected only on the ground that assessee has not opted for provisional assessment - AT
Refund claim - provisional assessment not opted - It is settled that even though the assessee has not opted for provisional assessment but the duty was paid in excess admittedly the assessee’s claim of refund within stipulated time of one year, the refund is admissible. The refund cannot be rejected only on the ground that assessee has not opted for provisional assessment - AT
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