Upward adjustment rejected as reimbursement of AMP expenses incurred by Sony India for AE was at arm’s length

PCIT Vs Sony India Pvt. Ltd. (Delhi High Court) Delhi High Court held that upward adjustment advertising, marketing and promotion expenses (AMP) rejected as reimbursement of AMP expenses incurred by respondent (Sony India) on behalf of its AE was at arm’s length. Facts- The present appeal is preferred by the appellant/revenue on the issue that whether the reimbursement of advertising, marketing and promotion expenses (AMP), incurred by the respondent/assessee on behalf of its Associated Enterprise (AE), was at arm’s length. In other words, whether any upward adjustment was required to be c...