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TMI Blog2015 (11) TMI 1796X X X X Extracts X X X X X X X X Extracts X X X X ..... said three issues in favour of the Assessee and that order has been upheld by the ITAT by the impugned order - HAs regards the above three issues, the Court is satisfied that no substantial question of law arises. TP Adjustment - Transactional Net Margin Method (TNMM) to the resale price method (RPM) as the most appropriate method (MAM) for the purposes of determination of the arms length price (A ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 617/Del/2014 for the Assessment Year ('AY') 2009-10. 4. Three of the questions urged by the Revenue in the present appeal concern the deletion of additions made by the Assessing Officer ('AO') on account of (a) prior period expenses, (b) provisions for warranty expenses and (c) non deduction of TDS under Section 40(a)(ia) of the Income Tax Act, 1961 ('Act'). Proceeding entirely on the basis of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ications India Pvt. Ltd. vs. Commissioner of Income Tax-III (2015) 374 ITR 118 (Del) that issue already stands remanded to the ITAT by this Court by an order dated 20th May, 2015 in the Assessee's appeal (ITA No.336/2015) against the same impugned order of the ITAT. 7. Consequently, this appeal is disposed of by upholding the impugned order of the ITAT on all issues except the issue concerning t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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