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...
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Valuation - treatment of the trade discount as additional consideration - The Tribunal noted that the transaction value should be determined based on commercial considerations, especially when the buyer and seller are not related. - The Tribunal distinguished the case from previous decisions involving oil marketing companies (OMCs) and upheld the appellant's contention that the transactions with OMCs were on a principal-to-principal basis. It was observed that there was no evidence of a service contract between the appellant and OMCs.
Valuation - treatment of the trade discount as additional consideration - The Tribunal noted that the transaction value should be determined based on commercial considerations, especially when the buyer and seller are not related. - The Tribunal distinguished the case from previous decisions involving oil marketing companies (OMCs) and upheld the appellant's contention that the transactions with OMCs were on a principal-to-principal basis. It was observed that there was no evidence of a service contract between the appellant and OMCs.
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