Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2017 (9) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2017 (9) TMI 1282 - ITAT DELHITPA - determination of ALP - TPO by applying the Bright Line Test (BLT) proposed adjustment on protective basis - Held that:- Following the decision rendered in case of Sony Ericsson Mobile Communications India (P.) Ltd. (2015 (3) TMI 580 - DELHI HIGH COURT) and Perfetti Van Melle India Pvt. Ltd. (2017 (5) TMI 1305 - ITAT DELHI), TP adjustment amounting to ₹ 22,30,18,964/- by applying BLT is not sustainable on protective basis having no statutory mandate. So, ground is determined in favour of the assessee.
|