Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
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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