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TMI Blog2024 (1) TMI 1404X X X X Extracts X X X X X X X X Extracts X X X X ..... CE DHARMESH SHARMA For the Appellant : Mr. Sanjeev Menon, Adv. for Mr. Zoheb Hossain, Sr. SC For the Respondent : Mr. Neeraj Jain, Mr. Aniket Agrawal, Mr. Abhishek Singhvi, Advs ORDER 1. The Department has preferred these appeals against the order of the Income Tax Appellate Tribunal ["ITAT"] dated 27 May 2019. The questions of law which are proposed for our consideration are as follows:- "A ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... mines the expenditure incurred by a routine distributor not promoting any marketing intangible? E. Whether the ITAT, on the facts and circumstances of the case, has erred in holding that existence of an International transaction must be established on the basis of the Hon'ble High Court's decisions in the cases of Maruti Suzuki India Ltd. v. CIT [2015] 381 ITR 117 (Delhi) and Sony Ericsson Mobil ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tances. This is evident from the following passage as appearing in the order of the ITAT:- "8. In our considered opinion, since basis on which adjustment has been made being Bright Line Test itself has been rejected by Hon'ble Delhi High Court in case of Sony Ericson India P. Ltd. (supra) and no further interference is called for at this stage. Further reliance placed by Ld.Sr.DR on BEPS guideli ..... X X X X Extracts X X X X X X X X Extracts X X X X
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