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...
SVLDRS - Rejection of declaration - Petitioner was subjected to audit as on the relevant date - There is no challenge to the audit proceedings before us. It is not possible to give a declaration in this Petition that the audit proceedings had deemed to have lapsed on 30 June 2019 as such a declaration is outside the scope of this proceeding, even assuming that such declaration can be given. - HC
SVLDRS - Rejection of declaration - Petitioner was subjected to audit as on the relevant date - There is no challenge to the audit proceedings before us. It is not possible to give a declaration in this Petition that the audit proceedings had deemed to have lapsed on 30 June 2019 as such a declaration is outside the scope of this proceeding, even assuming that such declaration can be given. - HC
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