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AMP Intensity & BLT Methods Rejected Again; ITAT Deletes Entire AMP Adjustment – Issues Remanded
Case Law Details
- Case Name
- Sony India Private Limited Vs ACIT (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 202-21
- Courts
- All ITAT, ITAT Delhi
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Sony India Private Limited Vs ACIT (ITAT Delhi)
Assesssee Wins Major TP Relief – ITAT Deletes Royalty, AMP & Stock Valuation Adjustments; Issues Remanded for Non-Speaking DRP Order
Assessee challenged multiple transfer pricing & corporate tax adjustments made in the assessment order passed u/s 143(3) r.w.s. 144C(13)/144B, pursuant to DRP directions. Assessee also sought admission of an additional ground (Ground 29) regarding DRP’s failure to pass a speaking order on comparables & classification of service income. Tribunal admitted the additional ground.
On comp...
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