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...
LTCG - ownership of property - Liability of power of attorney holder (GPA) - we are unable to persuade ourselves to subscribe to the view taken by the lower authorities who had brought the income/gain arising on the transfer of the property in question to tax in the hands of the assessee, who had merely facilitated the sale transaction in question in the status as that of a power of attorney holder for and on behalf of the actual owners - AT
LTCG - ownership of property - Liability of power of attorney holder (GPA) - we are unable to persuade ourselves to subscribe to the view taken by the lower authorities who had brought the income/gain arising on the transfer of the property in question to tax in the hands of the assessee, who had merely facilitated the sale transaction in question in the status as that of a power of attorney holder for and on behalf of the actual owners - AT
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