Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
Nominee director protection shields independent financial-institution appointees from criminal liability where they lack involvement in deposit defaul...
Bright Line Test is not a legally sanctioned method for transfer pricing adjustments relating to advertising, marketing and promotion expenses. Following the established position in Sony Ericsson and Maruti Suzuki, the High Court rejected the Department's use of that test for the impugned adjustment. The pendency of challenges to those precedents before the Supreme Court did not justify a different approach, although any contrary law subsequently declared in those proceedings would apply correspondingly.
Bright Line Test is not a legally sanctioned method for transfer pricing adjustments relating to advertising, marketing and promotion expenses. Following the established position in Sony Ericsson and Maruti Suzuki, the High Court rejected the Department's use of that test for the impugned adjustment. The pendency of challenges to those precedents before the Supreme Court did not justify a different approach, although any contrary law subsequently declared in those proceedings would apply correspondingly.
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