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...
TDS u/s 195 - non deduction of tax at source - Residential status of payee unknown - Bonafide belief that the payee is resident of India (who is non-resident) - This argument cannot be accepted as he was with the company since long time and this argument of the assessee do not come to present assessee’s rescue or absolve him of the duty to do what the law required the present assessee to do. - AT
TDS u/s 195 - non deduction of tax at source - Residential status of payee unknown - Bonafide belief that the payee is resident of India (who is non-resident) - This argument cannot be accepted as he was with the company since long time and this argument of the assessee do not come to present assessee’s rescue or absolve him of the duty to do what the law required the present assessee to do. - AT
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