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...
Rate of tax on assessed income of Non-Resident assessee - Partner in Joint Venture - Claim of Benefit of DTAA - to settle the matter at rest, the assessee is willing to offer the income subject to settlement of tax liability at the rate at which TDS has been deducted - The tribunal sustained the order of CIT(A) to tax the assessee's income at the rates provided under the India-Canada DTAA.
Rate of tax on assessed income of Non-Resident assessee - Partner in Joint Venture - Claim of Benefit of DTAA - to settle the matter at rest, the assessee is willing to offer the income subject to settlement of tax liability at the rate at which TDS has been deducted - The tribunal sustained the order of CIT(A) to tax the assessee's income at the rates provided under the India-Canada DTAA.
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