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...
TP Adjustment - Interest on External Commercial Borrowing (ECB) - The Tribunal found that the term of the ECB loan was indeed five years, not four years as asserted by the Revenue authorities. Considering past acceptance of similar interest rates by the TPO, the Tribunal ruled in favor of the assessee, allowing the interest payment on ECBs at the claimed rate.
TP Adjustment - Interest on External Commercial Borrowing (ECB) - The Tribunal found that the term of the ECB loan was indeed five years, not four years as asserted by the Revenue authorities. Considering past acceptance of similar interest rates by the TPO, the Tribunal ruled in favor of the assessee, allowing the interest payment on ECBs at the claimed rate.
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