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Bacardi India Pvt. Ltd. Versus Deputy Commissioner of Income Tax & Anr

2016 (11) TMI 1018 - DELHI HIGH COURT

Adoption of "Bright Line" Test - TPA - Held that:- This Court had categorically ruled against the adoption of the Bright Line Test while deciding host of issues, including Advertising, Marketing and Promotion expenditure (AMP) in the context of bench .....

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he assessee's appeal before the ITAT. The respondents are, therefore, directed to keep the demand in abeyance and not take any coercive measures till the final decision by the ITAT in the assessee's appeal. The final order of the ITAT shall be given .....

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ed by: Shri Nageswar Rao & Shri Sandeep S Karhail, Advs. Respondent Represented by: Shri Rahul Kaushik, Sr. Standing Counsel JUDGEMENT The petitioner seeks a direction for quashing of a demand by the revenue to the tune of over ₹ 33.65 cror .....

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CIT [ITA No.5140/Del/2011]. The assessee urges that the demand is per se unenforceable by reason of the later decision of this Court disapproving the Bright Line Test in Sony Ericsson Mobile Communications India Private Limited v. CIT 374 ITR 118. 2. .....

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