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...
Transfer pricing disputes resolved under the India-Japan MAP can be given effect only after the assessee withdraws the appeal ground covered by the resolution. Article 25 of the treaty was invoked for the transaction with Japanese associated enterprises, and the assessee stated that it would accept the competent authorities' resolution. Under Rule 44G, the Assessing Officer is to pass orders giving effect to the MAP resolution once the related appeal is withdrawn. The assessee accordingly requested withdrawal of the relevant ground, and the tax department raised no objection.
Transfer pricing disputes resolved under the India-Japan MAP can be given effect only after the assessee withdraws the appeal ground covered by the resolution. Article 25 of the treaty was invoked for the transaction with Japanese associated enterprises, and the assessee stated that it would accept the competent authorities' resolution. Under Rule 44G, the Assessing Officer is to pass orders giving effect to the MAP resolution once the related appeal is withdrawn. The assessee accordingly requested withdrawal of the relevant ground, and the tax department raised no objection.
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