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...
Valuation - The final assessment of the bills of entry, whereby a variance is brought about in the valuation of the subject goods, which is adverse to the interests of the petitioner, would have to be communicated to the affected party - Admittedly, in this case, the valuation of the subject goods, which forms part of 95 bills of entry, has been enhanced. The basis for enhancement of valuation, apparently, was not communicated to the petitioner. - HC
Valuation - The final assessment of the bills of entry, whereby a variance is brought about in the valuation of the subject goods, which is adverse to the interests of the petitioner, would have to be communicated to the affected party - Admittedly, in this case, the valuation of the subject goods, which forms part of 95 bills of entry, has been enhanced. The basis for enhancement of valuation, apparently, was not communicated to the petitioner. - HC
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