Now a days lot of TP discussion is going with reference to Bright line test. The concept of the same is new to the tax world and hence in this respect few briefings given below.
Routine or day-to-day marketing or sale promotion expenses even, when excessive and exorbitant, would not amount to ―brand building‖ expenses. It would be incorrect to treat advertisement as equivalent or synonymous with ―brand building‖ for the latter in commercial sense refers to several facets and components.
Delhi High Court Judgement.
TBM represented the recent path breaking decision rendered by the Delhi High Court (“DHC”), in the case of Sony Ericsson Mobile Communication India Pvt. Ltd. v CIT and a batch of 17 connected appeals and cross-appeals, dealing with Transfer Pricing dispute related to marketing intangible.