2015 (5) TMI 1103

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..... is not disputed by the parties that law has been since clarified by the Division Bench ruling in Sony Erricson Mobile Communications India Pvt. Ltd. vs. Commissioner of Income Tax-III (2015 (3) TMI 580 - DELHI HIGH COURT) . In these circumstances the order of the ITAT is modified. instead of applying the ratio of LG Electronics (supra), the matter is remitted to the ITAT for considering the merit .....

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..... ought not to have been considered as part of the AMP determination itself given their nature. 4. This Court notices that the ITAT in its impugned order in para 7.3 noticed that the Special Bench decision in L.G. Electronics India Pvt. Ltd. versus Assistant Commissioner of Income Tax, (2013) 152 TTJ 273 (Del), it is not disputed by the parties that law has been since clarified by the Division .....

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