https://www.taxtmi.com/caselaws?id=189822 AMP expenses could not be treated as a concluded international transaction issue where the assessee had specifically disputed that character before the DRP and ITAT. The Delhi HC held that, unlike in Sony Ericsson, the matter required fresh examination in light of the assessee's specific plea and the directions already issued in that decision. The ITAT's reliance on the Special Bench ruling in LG Electronics was therefore interfered with, and the order was set aside. The dispute was remanded to the ITAT for fresh adjudication, including whether AMP spending gave rise to an international transaction under Section 92B of the Income-tax Act, 1961. en-us Thu, 28 Jan 2016 00:00:00 +0530 Sat, 21 Jan 2017 17:58:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=189822 AMP expenses could not be treated as a concluded international transaction issue where the assessee had specifically disputed that character before the DRP and ITAT. The Delhi HC held that, unlike in Sony Ericsson, the matter required fresh examination in light of the assessee's specific plea and the directions already issued in that decision. The ITAT's reliance on the Special Bench ruling in LG Electronics was therefore interfered with, and the order was set aside. The dispute was remanded to the ITAT for fresh adjudication, including whether AMP spending gave rise to an international transaction under Section 92B of the Income-tax Act, 1961. Case-Laws Income Tax Thu, 28 Jan 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=189822