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2016 (11) TMI 1018 - DELHI HIGH COURT

2016 (11) TMI 1018 - DELHI HIGH COURT - TMI - 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 benchmarking international transactions while determining the Arm's Length Price (ALP). In the circumstances, the assessment and the order to the extent it resulted in substantial additions and the demand in q .....

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HAT & DEEPA SHARMA JJ Appellants Represented 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 crores. The ground urged in support of this petition is that in concluding the assessment, the Assessing Officer (AO) adopted the "Bright Line" Test favoured by the Special Bench of the Income Tax A .....

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