2016 (8) TMI 1175

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....cates. O R D E R The Revenue is aggrieved by the order of the Income Tax Appellate Tribunal ("ITAT") whereby the assessee's appeal against addition to the tune of Rs. 40,14,26,892/- made by the Assessing Officer on account of transfer pricing adjustment towards AMP (Advertisement, Marketing and Promotion) expenses was accepted and consequently the AO's order was rejected. The brief releva....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... the parties, the ITAT in this case noticed the subsequent discussion of the relevant principles applicable to deal with AMP expenses in ALP determination by a Bench of this Court in Sony Ericsson Mobile Communications India Pvt. Ltd. v. Commissioner of Income Tax - III, (2015) 218 DLT 449 (DB), and held that the bright line test espoused by the Revenue was inapplicable. As a result, the ITAT set ....