The Mumbai ITAT ruled that as per Explanation to section 92B of the Income tax Act, the transaction of business restructuring shall be considered an international transaction, irrespective of the fact whether it has a bearing on the profit, income, losses, or assets of such enterprises. The ITAT also upheld the disallowance of interest on Compulsory Convertible Debentures and treatment …
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 …
