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1 - 10 of 34 (0.32 seconds)Section 145A in The Income Tax Act, 1961 [Entire Act]
Section 14A in The Income Tax Act, 1961 [Entire Act]
Section 154 in The Income Tax Act, 1961 [Entire Act]
Section 35DDA in The Income Tax Act, 1961 [Entire Act]
Section 234C in The Income Tax Act, 1961 [Entire Act]
Section 145 in The Income Tax Act, 1961 [Entire Act]
Section 92 in The Income Tax Act, 1961 [Entire Act]
The Income Tax Act, 1961
Sony Ericsson Mobile Communications ... vs Commissioner Of Income Tax ??? Iii on 16 March, 2015
The Delhi bench of the tribunal
in some decisions including Perfetti Van Melle India (supra) has dealt
with the manner of computation of the ALP of the AMP expenses
incurred by manufacturers in the light of the judgment in the case of
Sony Ericsson (supra). No reasons, except the pendency of the matter in
the Hon'ble High Court in assessee's own case, have been given by the
ld. AR to claim departure from the view taken by the tribunal in earlier
103
ITA No.5120/Del/2010
ITA No.2441/Del/2012
cases. We, therefore, turn down the request of the ld. AR in this regard.
With these observations, we send the matter back to the file of TPO/AO
for a fresh determination of the ALP of the AMP expenses in accordance
with our above observations. In view of our decision in restoring the
issue of calculation of ALP of AMP expenses to the TPO/AO, the
assessee's appeal against the order passed by the AO/TPO u/s 154,
enhancing the amount of TP adjustment, would automatically be taken
care of in such fresh proceedings. We want to clarify that in such fresh
proceedings, the assessee will be at liberty to lead any fresh evidence in
support of its case.