Case Law Details
Case Name : Acer India Pvt. Ltd. Vs. DCIT (ITAT Bangalore)
Related Assessment Year : 2012-13
Courts :
All ITAT ITAT Bangalore
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Acer India Pvt. Ltd. Vs The Dy. Commissioner of Income-tax (ITAT Bangalore)
Hon’ble Delhi High Court has held in the case of Maruti Suzuki Ltd (supra) that the revenue needs to establish the existence of international transaction before undertaking benchmarking of AMP expenses. In the instant case, we notice that the TPO has entertained the belief on the basis of presumptions that the assessee’s AMP expenses have promoted the brand value of its AE, i.e., no material has been brought on record to show the existence of International transaction. Before us, the Ld A.R placed his reliance on v...
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Suggest to look through the expert article published and available in public domain on a search, titled- “Will Dispute Resolution Panels really be able to resolve disputes?”
In the light of the further bizarre developments since then, and the woeful field reality as of now, – mainly in the form of inconsistent itat and court decisions handed down- does not the title need to be reframed to read, – have DRPs really been able to resolve disputes; instead, not given rise to fresh kind of disputes, unlikely to be resolved in the foreseeable future ?!
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