DCIT, Chennai vs. Hyundai Motors India Ltd., Kancheepuram
In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...
ITA 761/CHNY/2016[2011-2012]Status: DisposedITAT Chennai27 Apr 2017AY 2011-2012
Section 143(3)Section 253(4)
…reign AE for the promotion of brand LG in India, which is legally owned by the latter. [Emphasis, by underlining, supplied by us] 19. The Special Bench then took note of Hon’ble Delhi High Court decision in the case of Maruti Suzuki India Ltd Vs ADIT [(2010) 328 ITR 510 (Del)], wherein, according to the special bench, it was held that “if the AMP expenses are incurred by a domestic entity which is an associated enterprise of foreign entity, then there is a requirement on the part of the foreign entity to compensate the domestic entity in respect of the advantage obtained by it in the form of brand building to th…