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2017 (11) TMI 386 - AT - Income TaxTPA - whether AMP adjustment could be made in the case of the assessee on protective basis following the Bright Line Test (BLT)? - Held that:- We find that BLT has been discarded as a method for computing arm’s length price for international transactions of AMP by the Hon’ble Delhi High Court in the case of Sony Ericsson Mobile Communications India Private Limited Vs. CIT (2015 (3) TMI 580 - DELHI HIGH COURT) thus, no addition could be sustained applying the BLT even on protective basis. Since in the year under consideration also, the only addition of AMP adjustment amounting to ₹ 42,90,27,103/- made applying BLT on protective basis has been challenged before us, respectfully following the above decision of the Tribunal, we direct the Assessing Officer to delete the said addition.
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