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2016 (8) TMI 1177 - HC - Income TaxTPA - AMP expenditure – Held that:- ITAT has remitted the matter for fresh consideration in the light of its previous Special Bench judgment in L.G. Electronics India Pvt. Ltd. v. ACIT (2013 (6) TMI 217 - ITAT DELHI). Since L.G. Electronics (supra) itself has been partially reversed and the matter has been remitted to be reconsidered in light of the directions in Sony Ericsson Mobile Communications India Private Limited v. CIT [2015 (3) TMI 580 - DELHI HIGH COURT] no question of law arises while considering the matter afresh. It goes without saying that the directions in Sony (supra) will be kept in mind and duly applied. Service charges agreed but not shown during the year under consideration - Held that:- On this, we notice that the principle of consistency was applied. Furthermore, this Court had in a previous order refused to frame a question of law (in Commissioner of Income Tax-I v. Bose Corporation India Pvt. Ltd.(2013 (7) TMI 1060 - DELHI HIGH COURT). No question of law arises. The appeals are accordingly dismissed as unmerited along with the pending application.
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