2022 (9) TMI 196

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....ujahid, Jr. Standing Counsel and Mr. Nikhil Jain, Advocate. Respondent Through: None J U D G M E N T MANMOHAN, J: (ORAL) 1. Present Income Tax Appeal has been filed challenging the Order dated 22nd January, 2021 passed by the Income Tax Appellate Tribunal ('ITAT') in ITA Nos.1619/Del/2016 and 1727/Del/2016 for the Assessment Year 2007-08. 2. Learned counsel for the appellant states ....

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....ony Ericsson (supra) has categorically held that Bright Line Test has no statutory mandate. The relevant extract of the judgement is reproduced hereinbelow: "The 'bright line test' has no statutory mandate and a broad-brush approach is not mandated or prescribed. We disagree with the Revenue and do not accept the overbearing and orotund submission that the exercise to separate &#3....

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....P.) Ltd. vs. Addl. CIT [2016] 65 taxmann.com 141 (Delhi) following the decision in Sony Ericsson (supra) held that the question of applying the Bright Line Test to determine the existence of an international transaction involving AMP expenditure does not arise. 6. Though the judgments of this Court have been challenged and are pending adjudication before the Supreme Court, yet there is no stay ....