https://www.taxtmi.com/caselaws?id=270790 A complete change in beneficial ownership of voting power can trigger the bar on carry forward and set-off of business losses under section 79, and common ultimate holding-company ownership does not by itself preserve the loss claim absent an arrangement showing continued beneficial ownership. The AMP transfer pricing issue must be examined on facts after Sony Ericsson: the Bright Line Test cannot by itself establish an international transaction, and an arm's length price adjustment arises only if such a transaction is first proved. The loss set-off claim failed, while the AMP issue was remanded for fresh consideration. en-us Wed, 13 Jan 2016 00:00:00 +0530 Tue, 03 May 2016 11:06:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=270790 A complete change in beneficial ownership of voting power can trigger the bar on carry forward and set-off of business losses under section 79, and common ultimate holding-company ownership does not by itself preserve the loss claim absent an arrangement showing continued beneficial ownership. The AMP transfer pricing issue must be examined on facts after Sony Ericsson: the Bright Line Test cannot by itself establish an international transaction, and an arm's length price adjustment arises only if such a transaction is first proved. The loss set-off claim failed, while the AMP issue was remanded for fresh consideration. Case-Laws Income Tax Wed, 13 Jan 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=270790