The Chennai ITAT deleted the ALP adjustment made towards The Bench comprising Mahavir Singh and Manoj Kumar Aggarwal on identical issue, noted that the Coordinate bench in assessee's own cases for AYs 2012-13 and 2016-17 deleted the adjustment holding that there was no formal agreement or arrangement between assessee and its AEs for rendering of service w.r.t alleged brand promotion …
The Delhi High Court has deleted the Bright Line Test -based Advertising, Marketing, and Promotion Adjustment for Yakult Danone for the non-existence of international transactions.The bench of Justice Rajiv Shakdher and Justice Girish Kathpalia has dismissed the department’s appeal, which challenged the ITAT’s order, and held that the "bright line test" has no statutory mandate. The Delhi High Court has …