ITAT Delhi Quashes AMP-related TP addition in Sony India matter

Sony India Pvt. Ltd. Vs ACIT (ITAT Delhi) Facts- 1. The assessee, Sony India Pvt. Ltd. (“SID”), appealed against final assessment orders for AY 2015–16 and AY 2017–18, challenging substantive and protective transfer pricing (TP) adjustments, corporate tax disallowances, and book profit computations under section 115JB. SID, a wholly owned subsidiary of Sony Corporation, Japan, is primarily engaged in distribution of consumer electronics in India and also renders advisory services to group companies. 2. International Transactions & TP Method – For FY 2014–15, SID entered int...