took with him the Investigating Officer („IO‟) kit
bag, field testing kit, electronic weighing machine and spring
weighing scale. He is stated to have made
ITAT in LG Electronics India Pvt.
Ltd. v. ACIT (2013) 140 ITD 41 (Del) adopted the 'Bright Line Test ... viii) The Bright Line Test was judicial legislation. By validating the
Bright Line Test the Special Bench in LG Electronics Case (supra)
went beyond Chapter
computing the net profit
margin. Once the comparables pass the functional analysis test and
adjustments have been made, then the profit margin as declared
when ... viii) The Bright Line Test was judicial legislation. By validating
the Bright Line Test the Special Bench in LG Electronics Case
went beyond Chapter
reimbursed by the foreign AE.
The ITAT's decision in LG Electronics
3. Before discussing the facts of the present case it requires ... viii) The Bright Line Test was judicial legislation. By validating
the Bright Line Test the Special Bench in LG Electronics Case
went beyond Chapter
majority of the
ITAT in LG Electronics was advocating the use of the bright line test for
the purposes of determining the existence as well ... viii) The Bright Line Test was judicial legislation. By validating the Bright
Line Test the Special Bench in LG Electronics Case went beyond Chapter
held that if the common parlance test
is applied, then ATMs would be considered as electronic devices and not
computer peripherals.
27. Applying the above
held that if the common parlance test
is applied, then ATMs would be considered as electronic devices and not
computer peripherals.
27. Applying the above
Acquisition System {Truck
chassis to be provided by ONGC)
ii. Cables, Ground electronics. Batteries with chargers
iii. Sensors
a. High sensitive Single Geophone ... like Thermal plotter,
colour monitors, ground electronic units with necessary
interfaces, cables. Radio Controlled Shooting System. Sensors,
Testing, Repair & maintenance systems and other
modules
accused.
(ii) Section 65(B)(1) EA states that copies of an electronic record transferred to another medium would be deemed to be a document ... followed by the CBI while investigating the case when it involves electronic records. A clone of the hard disc is expected to be prepared
computing the net profit margin. Once the
comparables pass the functional analysis test and adjustments
have been made, then the profit margin as declared when ... impermissible.
(viii) The Bright Line Test (BLT) was judicial legislation. By
validating the BLT the Special Bench in LG Electronics Case
went beyond Chapter