Continuation of Section 73 service-tax proceedings after provider's death (construing s.65(7)) - held to abate; posthumous OIO and recoveries invalida...
Change of corporate management after approved resolution plan - writ maintainable; property attachment not 'transfer' under PBPT; Section 32A protecti...
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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