Episode 7 (International Taxation)

Legal Wrangle's 7th episode is on International Taxation featuring the recent landmark decision of the Delhi High Court in the case of Sony Ericsson and others wherein the court held that bright line test and segregation of non routine AMP expenses has no legislative backing. The second case involves Madhusudan Rao, an NRI and Chairman of Lanco Infratech Ltd where the issue is whether foreign remittance from NRI's overseas account be treated as unexplained income under section 68 and 69. It also features Hyderabad Tribunal decision of Cyient Ltd that is about whether legal fees paid to foreign attorneys in connection with takeover of a company would be capital expense of deductible as revenue expenditure. The fourth case is from Delhi Tribunal involving Animal Planet where in the question is can resolution of lower rate under MAP invoked by group company be extended to Assesee? The final and fifth case is of Delhi High Court that involves Cotton Naturals (I) Pvt Ltd relating to Arm's length rate of interest charged by assess from his foreign subsidiary. The presenters are Aasha and Maneet.