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...
Income taxable/attribuable in India - attributed 15% of the assessee’s income to India - applicability of the Galileo rule[2009 (2) TMI 497 - DELHI HIGH COURT] - Galileo Nederland BV [supra] has now merged with the order of this Court in Travelport [2023 (5) TMI 227 - SUPREME COURT] filed by the Revenue before this Court. - Revenue appeal dismissed - SC
Income taxable/attribuable in India - attributed 15% of the assessee’s income to India - applicability of the Galileo rule[2009 (2) TMI 497 - DELHI HIGH COURT] - Galileo Nederland BV [supra] has now merged with the order of this Court in Travelport [2023 (5) TMI 227 - SUPREME COURT] filed by the Revenue before this Court. - Revenue appeal dismissed - SC
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