https://www.taxtmi.com/caselaws?id=350836 ITAT DELHI - AT set aside the impugned transfer-pricing orders and remitted matters to the AO/TPO for fresh ALP determinations: AMP expenditure must be re-assessed in line with the HC's Sony Ericsson ratio; receipt of IT support services must be benchmarked separately; procurement support and training services must be treated as functionally distinct and benchmarked independently after hearing the taxpayer. The Tribunal upheld the AO's treatment of DVRs as part of plant and machinery (allowing higher depreciation), not computer peripherals. en-us Fri, 10 Nov 2017 00:00:00 +0530 Fri, 24 Oct 2025 10:15:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=350836 ITAT DELHI - AT set aside the impugned transfer-pricing orders and remitted matters to the AO/TPO for fresh ALP determinations: AMP expenditure must be re-assessed in line with the HC's Sony Ericsson ratio; receipt of IT support services must be benchmarked separately; procurement support and training services must be treated as functionally distinct and benchmarked independently after hearing the taxpayer. The Tribunal upheld the AO's treatment of DVRs as part of plant and machinery (allowing higher depreciation), not computer peripherals. Case-Laws Income Tax Fri, 10 Nov 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=350836