Expenses for overseas film shooting treated as services availed outside India, so no reverse charge service tax liability; cenvat reversals and penalt...
Electricity consumptionbased clandestine production estimates under the repealed Central Excise Act found insufficient; demand quashed and appeals all...
Dominant issue: whether the Bright Line Test (BLT) is an appropriate benchmarking method for AMP expense allocation. The tribunal held that BLT is not a sustainable basis for transfer-pricing adjustment, relying on the precedent that rejected BLT for AMP allocations and emphasizing legal insufficiency of the AO/TPO's application of BLT; consequence: the adjustment/addition made to AMP expenses is deleted and the appeal is allowed. - ITAT
Dominant issue: whether the Bright Line Test (BLT) is an appropriate benchmarking method for AMP expense allocation. The tribunal held that BLT is not a sustainable basis for transfer-pricing adjustment, relying on the precedent that rejected BLT for AMP allocations and emphasizing legal insufficiency of the AO/TPO's application of BLT; consequence: the adjustment/addition made to AMP expenses is deleted and the appeal is allowed. - ITAT
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