Case Law Details
Case Name : Bausch & Lomb Eye care (India) Pvt. Ltd. Vs ACIT (Delhi High Court)
Related Assessment Year :
Courts :
All High Courts Delhi High Court
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Brief of the Case
Delhi High Court held In the case of Bausch & Lomb Eye care (India) Pvt. Ltd. that in the absence of any machinery provision, bringing an imagined transaction to tax is not possible. The decisions in CIT v. B.C. Srinivasa Setty (1981) 128 ITR 294 (SC) and PNB Finance Ltd. v. CIT (2008) 307 ITR 75 (SC) make this position clears. Therefore, where the existence of an international transaction involving AMP expense with an ascertainable price is unable to be shown to exist, even if such price is nil, Chapter X provisions cannot be invoked to undertake a TP adjustment exercis...
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