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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 ..... omotion (AMP) adjustment - HELD THAT:- ITAT has rendered the impugned order following the judgment rendered by our Court in Sony Ericsson Mobile Communications India (P.) Ltd. [ 2015 (3) TMI 580 - DELHI HIGH COURT] and which had rejected the application of the Bright Line Test in all circumstances. We find that these appeals raise no substantial question of law. - HON'BLE MR. JUSTICE YASHWAN ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 0AB of the Income Tax Rules? C. Whether the ITAT, on the facts and circumstances of the case, has erred in rejecting the TPO s bright line approach in determining Arm s Length Price for the AMP expenditure incurred by the assessee? D. Whether the ITAT, on the facts and circumstances of the case, has erred in not accepting the TPO s view that Bright Line concept is an internationally accepted econo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... thod for AMP adjustment as unsustainable when the matter is sub-judice and is pending with the Hon ble Supreme Court? 2. We note that the ITAT has rendered the impugned order following the judgment rendered by our Court in Sony Ericsson Mobile Communications India (P.) Ltd. vs. Commissioner of Income-tax-III [2015 SCC Online Del 8083] and which had rejected the application of the Bright Line Test ..... X X X X Extracts X X X X X X X X Extracts X X X X
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