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TMI Blog2020 (12) TMI 517X X X X Extracts X X X X X X X X Extracts X X X X ..... LG Electronics India Pvt. Ltd. [ 2013 (6) TMI 217 - ITAT DELHI] - HELD THAT:- The said judgment of the Special Bench has already been set aside [ 2016 (1) TMI 582 - DELHI HIGH COURT] TPO is directed to determine the cost/ value of international transactions. Accordingly, the impugned order of the ITAT is set aside to a limited extent and the TPO is directed to decide the matter in accorda ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 4 factors for determining the cost/ value of international transactions in accordance with the Special Bench order passed immediately preceding year of the respondent-assessee in LG Electronics India Pvt. Ltd. vs. ACIT 2013 152 TTJ (Del) (SB) 273. 3. Mr. Ajit Sharma states that the said judgment of the Special Bench has already been set aside by the learned Predecessor Division Bench vide ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... xist, that the further question of determining the ALP of such international transaction would arise. 27. It is not possible to state that the Revenue has not placed any material to even prima facie show the existence of an agreement regarding AMP expenses. The question however remains whether it discloses an international transaction between Yum India and its AE in regard to AMP expenses f ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tion of determination of its ALP to the AO /TPO for a fresh decision in light of the judgment of this Court in Sony Ericsson Mobile Communication India P. Ltd. (supra). The question framed is answered in the affirmative. 4. Learned counsel for the respondent also has no objection if the TPO is directed to decide the remand in accordance with the Division Bench order in ITA Nos.349/2015 and ..... X X X X Extracts X X X X X X X X Extracts X X X X
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