Transfer-pricing aggregation of distinct support-service and subcontract transactions was rejected, while debt-free receivables attracted no notional ...
Customs exemptions cover photovoltaic assembly machinery and PVF backsheets, while fully declared cleared imports may avoid confiscation and penalties...
Specific tariff classification for LCD devices overrides treatment as electricity-meter parts, defeating differential duty, extended limitation, and p...
Stayed disciplinary punishment does not establish unfitness for insolvency professional registration; reconsideration must disregard mere pendency of ...
Indirect corporate control can create related-party status, excluding financial creditors from Committee of Creditors representation, participation an...
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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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