Bright Line Test rejected in transfer pricing dispute as no substantial question of law arose.

The Delhi HC held that the appeal did not raise any substantial question of law from the ITAT's deletion of the AMP adjustment and rejection of the Bright Line Test. The ITAT had followed Sony Ericsson Mobile Communications India (P.) Ltd., which rejected application of the Bright Line Test in all circumstances. On that basis, the court found no ground for interference, did not entertain the appeal on merits, and left the impugned order undisturbed in favour of the assessee.

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Issues: Whether the appeal raised any substantial question of law arising from the ITAT's deletion of the AMP adjustment and rejection of the Bright Line Test.

Analysis: The impugned order of the ITAT followed the Delhi High Court's decision in Sony Ericsson Mobile Communications India (P.) Ltd., which had rejected application of the Bright Line Test in all circumstances. On that footing, the Court held that the proposed questions did not give rise to any substantial question of law warranting interference.

Conclusion: The appeal was not entertained on merits and the impugned order was left undisturbed, in favour of the assessee.

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