A recent decision of the Chennai Income Tax Appellate Tribunal has been published concerning whether an increase in an MNE's global brand value may result in the attribution of notional income for its Indian subsidiary for local brand development activities. The case involves Hyundai Motor India Limited and three sets of appeals for the assessment years 2009-10, 2010-11 and 2011-12. Hyundai India is engaged in the business of manufacturing cars in India under the Hyundai brand.
For the years…