https://www.taxtmi.com/caselaws?id=347619 ITAT DELHI - AT set aside the transfer pricing adjustment on AMP expenses and remitted the matter to the TPO/AO to determine the ALP afresh, directing adherence to the High Court's Sony Ericsson benchmark methodology and requiring detailed functional analysis of AMP activities for the assessee and comparables. The tribunal rejected the use of an unexplained 5% mark-up and found the record insufficient to benchmark AMP. Separately, the tribunal denied deduction for interest on customs duty in the year under assessment, permitting the assessee to claim it in the year the interest was actually paid. en-us Fri, 01 Sep 2017 00:00:00 +0530 Fri, 24 Oct 2025 10:16:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=347619 ITAT DELHI - AT set aside the transfer pricing adjustment on AMP expenses and remitted the matter to the TPO/AO to determine the ALP afresh, directing adherence to the High Court's Sony Ericsson benchmark methodology and requiring detailed functional analysis of AMP activities for the assessee and comparables. The tribunal rejected the use of an unexplained 5% mark-up and found the record insufficient to benchmark AMP. Separately, the tribunal denied deduction for interest on customs duty in the year under assessment, permitting the assessee to claim it in the year the interest was actually paid. Case-Laws Income Tax Fri, 01 Sep 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=347619