2024 (9) TMI 648 - HC - Income Tax

Advertisement, Marketing and Promotion AMP computation - adoption of the Bright Line Test - HELD THAT - We had in terms of our order 2024 (4) TMI 1176 - DELHI HIGH COURT decided all the principal questions and had left it open for learned counsels to address submissions on the question of Advertisement, Marketing and Promotion AMP . Upon going through the order of ITAT and insofar as it deals with the aforesaid issue, we find that the AMP computation was based on the adoption of the Bright Line Test. That would clearly not sustain in light of the judgement rendered by the Court in Sony Ericson 2015 (3) TMI 580 - DELHI HIGH COURT We find no merit in these appeals.

Summary

The High Court dismissed the appeals as the AMP computation based on the Bright Line Test was not sustainable in light of the judgment in Sony Ericson v. CIT [2015 SCC OnLine Del 8083]. The appeals were found to have no merit.