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COMMISSIONER OF INCOME TAX –I Versus MIS AMADEUS INDIA PVT. LTD. AND AMADEUS INDIA PVT. LTD.

2015 (6) TMI 590 - DELHI HIGH COURT

Disallowance of selling expenses - determination of AMP expenses - Held that:- The decision of the LG Electronics (2013 (6) TMI 217 - ITAT DELHI) and all questions concerning the tax implications and transfer pricing arising therefrom in AMP related .....

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the subject matter of these proceedings – including incentives paid to distributors and dealers for services rendered are treated as AMP expenses and, therefore, held to be excluded from the determination of transfer pricing.

In the ligh .....

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notice that the matter was remitted for fresh consideration to the AO who was bound by the decision in Sony (supra). - ITA 535/2014, ITA 729/2014, C.M. APPL.19449-19450/2014 - Dated:- 15-4-2015 - MR. S. RAVINDRA BHAT AND MR. R.K.GAUBA, JJ. For the A .....

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ncome Tax Act, 1961 (hereafter referred to as the Act ), the Revenue is aggrieved by the order dated 06.03.2014 of the Income Tax Appellate Tribunal (ITAT) in ITA No.4584/Del/2011. The respondent/assessee has also appealed against a part of the same .....

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t the assessee is engaged in the business of providing data processing and related services to its associated enterprises. It enables software access to the subscribers of the Amadeus products and computer database within Indian subcontinent. To that .....

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passed on to assessee s distributors and local dealers, who were performing the role of travel agents to intensively utilize all services and the media group s website. The Assessing Officer (AO) referred the matter to the Transfer Pricing Officer (T .....

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gment reduced the amount to ₹ 33,52,43,720/-. The revenue appealed to the ITAT, which in the light of the Special Bench decision in LG Electronics (supra) allowed the assessee s contentions and held that the expenses to the tune of ₹ 54.7 .....

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cs (supra). The decision of the LG Electronics (supra) and all questions concerning the tax implications and transfer pricing arising therefrom in AMP related matters was considered by the Division Bench judgment of this Court in Sony Ericsson Mobile .....

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