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 - Nature of discount offered to Distributors and not to other buyers - Section 4 essentially seeks to accept different transaction value which may be charge by an assessee from it different buyers - It is found that since the sale invoice which have been issued to the distributors by the appellant offering 15 % discount is normally a trade discount and the department has failed to discharge its responsibility to establish that there has been any flow back of consideration from buyer to the appellant. - Value not to be added - AT
Valuation - Nature of discount offered to Distributors and not to other buyers - Section 4 essentially seeks to accept different transaction value which may be charge by an assessee from it different buyers - It is found that since the sale invoice which have been issued to the distributors by the appellant offering 15 % discount is normally a trade discount and the department has failed to discharge its responsibility to establish that there has been any flow back of consideration from buyer to the appellant. - Value not to be added - AT
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