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...
Valuation of imported goods - aluminium scrap - enhancement of value - The Tribunal referred to a previous decision where it was asserted that the appellant had agreed to the enhanced value as determined by the department. However, the appellant vehemently denied giving such consent. Given the serious dispute over consent, the Tribunal decided that this core issue needed resolution before relying on any precedent. Consequently, the Tribunal decided to send the matter back to the Division Bench for a decision on this core issue.
Valuation of imported goods - aluminium scrap - enhancement of value - The Tribunal referred to a previous decision where it was asserted that the appellant had agreed to the enhanced value as determined by the department. However, the appellant vehemently denied giving such consent. Given the serious dispute over consent, the Tribunal decided that this core issue needed resolution before relying on any precedent. Consequently, the Tribunal decided to send the matter back to the Division Bench for a decision on this core issue.
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