2015 (6) TMI 590

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..... Standing Counsel with Sh. Shikhar Garg, Advocate For the Respondent : Sh. Mayank Nagi, Advocate ORDER This matter is taken up today since 14.04.2015 was declared a holiday. In this appeal under Section 260-A of the Income Tax Act, 1961 (hereafter referred to as "the Act"), the Revenue is aggrieved by the order dated 06.03.2014 of the Income Tax Appellate Tribunal (ITAT) in ITA No.458....

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....these were direct expenditure passed on to assessee's distributors and local dealers, who were performing the role of travel agents to intensively utilize all services and the media group's website. The Assessing Officer (AO) referred the matter to the Transfer Pricing Officer (TPO) who was of the opinion that these expenses constituted advertising, marketing and promotional expenditure, i.e. AMP ....

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....e Division Bench judgment of this Court in Sony Ericsson Mobile Communications India Private Limited v. CIT-III (ITA 16/2014, decided on 16.03.2015). In the said decision, direct selling expenses such as the one which are the subject matter of these proceedings - including incentives paid to distributors and dealers for services rendered are treated as AMP expenses and, therefore, held to be exclu....