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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Transfer pricing disputes concerned reimbursements of personnel cost, IT-related expenses, advertisement and publicity expenses, and royalty. The Tribunal upheld deletion of adjustments on personnel cost and IT-related reimbursements because the assessee showed they were pure cost-to-cost items, with supporting material and no markup; the personnel-cost issue was also covered by the assessee's earlier years' orders. The Tribunal sustained the adjustment on advertisement and publicity reimbursement because the assessee failed to produce documentary evidence establishing the need for and incurrence of the . The royalty adjustment was deleted on consistency, the issue being covered by the assessee's own earlier order.
Transfer pricing disputes concerned reimbursements of personnel cost, IT-related expenses, advertisement and publicity expenses, and royalty. The Tribunal upheld deletion of adjustments on personnel cost and IT-related reimbursements because the assessee showed they were pure cost-to-cost items, with supporting material and no markup; the personnel-cost issue was also covered by the assessee's earlier years' orders. The Tribunal sustained the adjustment on advertisement and publicity reimbursement because the assessee failed to produce documentary evidence establishing the need for and incurrence of the . The royalty adjustment was deleted on consistency, the issue being covered by the assessee's own earlier order.
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