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Sony Ericsson Mobile Communications ... vs Commissioner Of Income Tax ??? Iii on 16 March, 2015

9. Ms. Vibhuti Malhotra, counsel for the revenue, refuted the assesseeā€Ÿs submissions. She urged firstly that Sony Ericsson (supra) does not stipulate any invariable rule with respect to aggregation or desegregation of transactions. Rather, it merely endorsed the view that aggregation is desirable. It was argued that while the commercial decision- making and choices of an entity are to be largely left intact, this court recognized that in ALP determination, it is essential that there are two exceptions to the principle:
Delhi High Court Cites 49 - Cited by 38 - S Khanna - Full Document
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