2016 (8) TMI 1175

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..... come Tax - III [2015 (3) TMI 580 - DELHI HIGH COURT] and held that the bright line test espoused by the Revenue was inapplicable. As a result, the ITAT set aside the additions made by the lower authorities. Having considered the submissions, this Court is of the opinion that there is no reason to differ with the reasoning in Sony Ericsson (supra) which is the sole basis for the impugned order. .....

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..... international transactions and determining its arms length price vis- -vis business/transactions with the Associated Enterprise (AE). The TPO (Transfer Pricing Officer) and subsequently the AO accepted the other parts of the exercise but observed that AMP expenses to the tune of ₹ 45,27,63,518/- including discounts were incurred. The AO by the final order added ₹ 40.14 Crores on this a .....

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