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2015 (6) TMI 590 - DELHI HIGH COURT

2015 (6) TMI 590 - DELHI HIGH COURT - TMI - 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 matters was considered by the Division Bench judgment of this Court in Sony Ericsson Mobile Communications India Private Limited v. CIT-III (2015 (3) TMI 580 - DELHI HIGH COURT). In the said decision, direc .....

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ount of ₹ 3.91 crores is concerned, we 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 Appellant : Sh. Kamal Sawhney, Sr. Standing Counsel with Sh. Shikhar Garg, Advocate For the Respondent : Sh. Mayank Nagi, Advocate ORDER This matter is taken up today since 14.04.2015 was declared a holiday. .....

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41 (Del)/(SB). The facts of the case are that 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 end, it provides connectivity to host systems by creation/modification of computer programs online. Inter alia, it claimed deduction of ₹ 58,66,30,490/- on account of selling expenses. The assessee c .....

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