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...
Customs valuation of imported cyanuric chloride - revenue rejected declared value based on NIDB and contemporaneous import data showing higher prices for smaller quantities - appellant imported 2000 MT at lower negotiated price - CESTAT held quantity imported significantly different from NIDB data relied upon by revenue, hence cannot be compared - no other evidence cited by authorities - orders set aside, appeal allowed.
Customs valuation of imported cyanuric chloride - revenue rejected declared value based on NIDB and contemporaneous import data showing higher prices for smaller quantities - appellant imported 2000 MT at lower negotiated price - CESTAT held quantity imported significantly different from NIDB data relied upon by revenue, hence cannot be compared - no other evidence cited by authorities - orders set aside, appeal allowed.
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