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TMI Blog2015 (6) TMI 590X X X X Extracts X X X X X X X X Extracts X X X X ..... as considered by the Division Bench judgment of this Court in Sony Ericsson Mobile Communications India Private Limited v. CIT-III (2015 (3) TMI 580 - DELHI HIGH COURT). In the said decision, direct selling expenses such as the one which are the subject matter of these proceedings – including incentives paid to distributors and dealers for services rendered are treated as AMP expenses and, therefo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ared a holiday. In this appeal under Section 260-A of the Income Tax Act, 1961 (hereafter referred to as the Act ), the Revenue is aggrieved by the order dated 06.03.2014 of the Income Tax Appellate Tribunal (ITAT) in ITA No.4584/Del/2011. The respondent/assessee has also appealed against a part of the same order in the accompanying proceeding, being ITA No.729/2014 in respect of the remand di ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ces and the media group s website. The Assessing Officer (AO) referred the matter to the Transfer Pricing Officer (TPO) who was of the opinion that these expenses constituted advertising, marketing and promotional expenditure, i.e. AMP expenses. An adjustment of ₹ 52,33,73,988/- was proposed. The assessee s appeal to the DRP succeeded partly, in that the judgment reduced the amount to ₹ ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 015). In the said decision, direct selling expenses such as the one which are the subject matter of these proceedings including incentives paid to distributors and dealers for services rendered are treated as AMP expenses and, therefore, held to be excluded from the determination of transfer pricing. In the light of this decision, this Court is of the opinion that the main question as to the cor ..... X X X X Extracts X X X X X X X X Extracts X X X X
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