Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
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The HC upheld the ITAT's decision to delete additions related to AMP expenditure incurred by the assessee for brand-building owned by an associated enterprise. The court determined that while Section 92B defines "international transaction" (expanded by Finance Act 2012's Explanation to include "use" of intangible property retroactively from April 2002), the Revenue failed to establish the existence of an actual transaction. The TPO erroneously relied solely on perceived excessive AMP expenditure and applied the Bright Line Test, which had been previously criticized in Maruti Suzuki. The deeming fiction introduced in Section 92B(2) was inapplicable due to the absence of a prior agreement and its prospective application from April 2015. The ITAT's decision required no interference.
The HC upheld the ITAT's decision to delete additions related to AMP expenditure incurred by the assessee for brand-building owned by an associated enterprise. The court determined that while Section 92B defines "international transaction" (expanded by Finance Act 2012's Explanation to include "use" of intangible property retroactively from April 2002), the Revenue failed to establish the existence of an actual transaction. The TPO erroneously relied solely on perceived excessive AMP expenditure and applied the Bright Line Test, which had been previously criticized in Maruti Suzuki. The deeming fiction introduced in Section 92B(2) was inapplicable due to the absence of a prior agreement and its prospective application from April 2015. The ITAT's decision required no interference.
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