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2022 (12) TMI 239 - AT - Income TaxTP Adjustment - use of BLT approach by the TPO - Benchmarking of AMP expenditure - Bright line concept (Protective Adjustment) - addition in respect of ALP adjustment made on protective basis by applying BLT - HELD THAT:- d. DR could not cite any factual distinction or different proposition of law then followed in the assessee’s own case [2019 (10) TMI 1536 - DELHI HIGH COURT] for aforesaid previous years as relying on Sony Ericsson case [2015 (3) TMI 580 - DELHI HIGH COURT]. Consequently the grounds pressed are sustained and appeal is allowed and the adjustment proposed on BLT approach is set aside.
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