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2015 (11) TMI 1796 - HC - Income TaxAddition of prior period expenses, provisions for warranty expenses and non deduction of TDS under Section 40(a)(ia) - HELD THAT:- Commissioner of Income Tax (Appeals) decided the said three issues in favour of the Assessee and that order has been upheld by the ITAT by the impugned order - HAs regards the above three issues, the Court is satisfied that no substantial question of law arises. TP Adjustment - Transactional Net Margin Method (TNMM) to the resale price method (RPM) as the most appropriate method (MAM) for the purposes of determination of the arms length price (ALP) - HELD THAT:- The Court sees no reason to interfere since the adoption of the RPM by the Assessee was indeed found to be the MAM by the Dispute Resolution Panel (DRP) itself. AMP expenses - in view of the judgement of this Court in Sony Ericsson Mobile Communications India Pvt. Ltd. vs. Commissioner of Income Tax-III [2015 (3) TMI 580 - DELHI HIGH COURT] issue already stands remanded to the ITAT.
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