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...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Determination of residential status and place of earning the income of the company - Sikkim or Delhi (India) - place of control and management at Delhi - the business conducted/done in Sikkim - The findings of fact recorded by the AO, confirmed by the CIT(A) that the control and management of the affairs of the assessee companies was with Auditor (CA) at Delhi are based on the entire material on record. - SC
Determination of residential status and place of earning the income of the company - Sikkim or Delhi (India) - place of control and management at Delhi - the business conducted/done in Sikkim - The findings of fact recorded by the AO, confirmed by the CIT(A) that the control and management of the affairs of the assessee companies was with Auditor (CA) at Delhi are based on the entire material on record. - SC
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