https://www.taxtmi.com/caselaws?id=447087 The Income Tax Appellate Tribunal ruled in favor of the respondent/assessee for AY 2010-11, similar to AY 2008-09, deciding that the AMP expenses did not constitute an international transaction. The Tribunal rejected the TPO's application of the Bright Line Test, requiring proof of a transaction between the assessee and its associated enterprise. The matter was remitted to the Assessing Officer. The appeal was closed, with a potential for revival contingent on the outcome of a pending Special Leave Petition in Sony Ericsson. An application for delay condonation was deemed unnecessary. en-us Fri, 01 Dec 2023 00:00:00 +0530 Wed, 18 Feb 2026 16:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=447087 The Income Tax Appellate Tribunal ruled in favor of the respondent/assessee for AY 2010-11, similar to AY 2008-09, deciding that the AMP expenses did not constitute an international transaction. The Tribunal rejected the TPO's application of the Bright Line Test, requiring proof of a transaction between the assessee and its associated enterprise. The matter was remitted to the Assessing Officer. The appeal was closed, with a potential for revival contingent on the outcome of a pending Special Leave Petition in Sony Ericsson. An application for delay condonation was deemed unnecessary. Case-Laws Income Tax Fri, 01 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=447087