Separate AMP adjustment uncalled as distribution business benchmarked separately

PCIT Vs Sony India Private Limited (Delhi High Court)

Delhi High Court held that separate transfer pricing adjustment for AMP was uncalled for given that the distribution business of assessee was already benchmarked separately and the transaction was benchmarked correctly.

Facts- Vide the present appeal, revenue has mainly contested that the Hon’ble ITAT was justified in holding that a separate AMP adjustment was uncalled for given that the distribution business of the Respondent was already benchmarked separately, when the TPO had treated it as a separate

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