2017 (3) TMI 1535 - HC - Income Tax

Treatment of AMP expenses - whether they are to be considered as an international transaction - Royalty and technical guidance fee - whether it is revenue or capital expenditure - Held that - the Rulings of the Income Tax Appellate Tribunal (ITAT) for the previous years have been upheld by this Court in Honda Siel Power Products Ltd. v. DCIT 2015 (12) TMI 1333 - DELHI HIGH COURT and CIT v. Honda Siel Power Products Ltd 2017 (5) TMI 469 - DELHI HIGH COURT . No substantial question of law, therefore, arises on these aspects. - Decided against revenue Commission paid - whether the assessee was liable to deduct tax at source under Section 195 - Held that - issue notice.

Summary

The High Court of Delhi upheld rulings on AMP expenses and royalty/technical guidance fees. No substantial question of law arose on these aspects. The court issued notice on the question of commission paid and tax deduction under Section 195. Case listed for further hearing on 08.05.2017.