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2017 (12) TMI 125 - AT - Income TaxAddition on AMP adjustment - addition made on protective basis following the BLT method was sustained by the ld. DRP - Held that:- We find that the BLT for computing Arm’s Length Price of AMP transaction has already been rejected by the Hon’ble Delhi High Court in the case of Sony Ericsson (2015 (3) TMI 580 - DELHI HIGH COURT) and thus adjustment even protective basis cannot be sustained. The decision of the Hon’ble Jurisdictional High Court is a binding precedent and the lower authorities cannot disregard it merely because the Revenue has challenged it before the Hon’ble Supreme Court. Thus, respectfully following the above decision of the Tribunal, we direct the Ld. AO/TPO to delete the protective addition. Accordingly, we allow the relevant grounds of the appeal of the assessee. Disallowance of additional claim of deduction pursuant to the order of the Settlement Commission - Held that:- In view of the findings of Tribunal in assessment year 2012-13 and provision of Section 43B of the Act, deduction for payment of interest is not allowable in the year under consideration.
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