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2019 (1) TMI 1341 - AT - Income TaxTPA - BLT method for proposing adjustment for AMP expenditure - Held that:- In present facts of the case, substantive as well as protective assessment both has been made in the hands of same assessee for same year under consideration on AMP expenditure by learnt TPO. On objection being raised by assessee before DRP against the adjustment proposed, a direction was issued to AO/TPO to make adjustment to in respect of AMP expenditure by following intensity method, being the plausible method. DRP has followed view in case of CIT vs. Sony Ericson Mobile Communication India Pvt.Ltd., (2015 (9) TMI 483 - ITAT DELHI) to reject BLT method for proposing adjustment for AMP expenditure. Thus respectfully following Hon’ble Delhi High Court, we hold that adjustment made on protective basis by following bright line test is not sustainable.
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