Minimum Public Offer Requirements set tiered issuer-based allotment minima with mandatory staged public shareholding increases and exchange enforcemen...
Disallowance under tax law for investment expenses cannot be applied mechanically; authority must record clear reasons before increasing assessee's su...
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Transfer pricing dispute over benchmarking of AMP expenses and appropriate ALP method: the Bright Line Test (BLT) adjustments are held legally unsustainable and deleted; the Cost Plus method is rejected as unjustified because the assessee acted as a distributor incurring routine business promotion and employee costs that should form part of trading cost; the tribunal accepts comparability under adjusted TNMM and directs an ALP uplift equal to the difference between the comparable PLI and the assessee's margin, instructing the AO to compute and apply that limited adjustment in line with the cited Sony Ericsson precedent.
Transfer pricing dispute over benchmarking of AMP expenses and appropriate ALP method: the Bright Line Test (BLT) adjustments are held legally unsustainable and deleted; the Cost Plus method is rejected as unjustified because the assessee acted as a distributor incurring routine business promotion and employee costs that should form part of trading cost; the tribunal accepts comparability under adjusted TNMM and directs an ALP uplift equal to the difference between the comparable PLI and the assessee's margin, instructing the AO to compute and apply that limited adjustment in line with the cited Sony Ericsson precedent.
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