Nokia India (P.) Ltd. v Addln CIT [2012] 22 taxmann.com 109 (Delhi – Trib.) Facts of the case Assessee incurred certain advertisement, marketing and promotion expenditure. The AO in order to determine the arm’s length price of international transaction with associated enterprise referred the matter to TPO u/s 93CA(3) of the act. The TPO passed an order u/s 92CA(3) of the Act, wherein he determined the arm’s length price on Advertisement, Marketing and Promotion (AMP) expenses amounting to Rs. 253,48,30,000.
Budget 2012
The Finance Bill, 2012 was introduced in Parliament on 16 March 2012. Certain official amendments have been carried out during the passage of the Bill in Parliament. A supplementary memorandum elucidating the official amendments to the Finance Bill, 2012 as reflected in the Finance Act, 2012 enacted on 28 May 2012, is attached. Click here to download
Amendments to Finance Bill, 2012 – Supplementary Memorandum
Press Release dated 15.5.2012 issued by the Ministry of Finance: Following government amendments have been proposed in the provisions relating to General Anti-Avoidance Rules (GAAR) contained in the Finance Bill 2012.
Amended GAAR Provisions In Finance Bill 2012: Press Release
The Finance Minister through the Union Budget 2012-13 has introduced several amendments in the income-tax law having far reaching implications on the tax payers. A key tax proposal introduced is the General Anti-Avoidance Rules (GAAR) which intends to address the issue of aggressive tax planning and codify the doctrine of “substance over form”. GAAR is proposed to be implemented with effect from AY 2013-14. Click here to download the article