Consequential appeal-effect orders must implement rectification deleting working-capital adjustments and reconsider the resulting arm's-length range c...
Discounted cash flow valuation protects share premium where projections are reasonable, while audited book expenses defeat unexplained-expenditure add...
Section 54 construction relief survives pre-transfer commencement when completion occurs within the statutory period, excluding ineligible spouse-owne...
Fraud classification show-cause notices founded on inconclusive forensic audit material cannot sustain action, permitting fresh proceedings on conclus...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4883 
