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 of imported goods - the onus of proving charge of undervaluation lies on the Revenue which needs to be proved by way of producing necessary evidence - the revenue erred in rejecting the invoice price - revenue is unable to provide any clinching evidence to prove undervaluation by the importer so as to reject the transaction value given in the invoice. - Revenue appeal dismissed - AT
Valuation of imported goods - the onus of proving charge of undervaluation lies on the Revenue which needs to be proved by way of producing necessary evidence - the revenue erred in rejecting the invoice price - revenue is unable to provide any clinching evidence to prove undervaluation by the importer so as to reject the transaction value given in the invoice. - Revenue appeal dismissed - AT
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