2016 (10) TMI 1073

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....rawal For the Revenue/Respondent : Asheesh Jain, Sr. Standing Counsel ORDER C.M.38904/2016 in ITA711/2016 C.M.38906/2016 in ITA 712/2016 C.M.38908/2016 in ITA 713/2016 (for delay in refiling) For the reasons mentioned in the applications delay in refiling the appeals is condoned. The applications stand disposed of. C.M.38905/2016 in ITA711/2016 C.M.38907/2016 in ITA 7....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....uch appellant before this court. The observations in Sony Ericsson Mobile Communications India P. Ltd.'s case (supra), in this regard is contained in the decision especially in paras 164 to 168 and 193 of the judgment. Particularly, this court held that (a) AMP expenses fall within the matrix of international transactions and are necessarily to be included in ALP determination; (b) there can be no....