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Transfer PricingArticle·29 July 2026

Bright Line Test Rejected

By J the App

Executive Summary

The Delhi ITAT held that the adjustment, being founded on the Bright Line Test, could not survive in view of the binding judgment of the Delhi High Court in Sony Ericsson Mobile Communications India Pvt. Ltd., while making the outcome subject to the final decision of the Supreme Court in the pending appeal.

Domain | Corporate Tax | Transfer Pricing

Background

The assessee, a subsidi...

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