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 - disallowance u/s. 40(a)(i) for non deduction of TDS on payment to non-resident which is in nature of FTS(Fee for Technical Service) - beneficial provisions of India-Netherland DTAA - The services in question did not meet the criteria of 'make available' under the India-Netherlands tax treaty. Hence, the payments for these services were not subject to TDS under section 195 and not disallowable under section 40(a)(i). - AT
TDS u/s 195 - disallowance u/s. 40(a)(i) for non deduction of TDS on payment to non-resident which is in nature of FTS(Fee for Technical Service) - beneficial provisions of India-Netherland DTAA - The services in question did not meet the criteria of 'make available' under the India-Netherlands tax treaty. Hence, the payments for these services were not subject to TDS under section 195 and not disallowable under section 40(a)(i). - AT
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