TMI Blog2019 (8) TMI 516X X X X Extracts X X X X X X X X Extracts X X X X ..... I HIGH COURT] and CIT vs. Honda Siel Power Products Limited [ 2016 (1) TMI 1283 - DELHI HIGH COURT] whereby the issue stands answered in favour of the Assessee. Accordingly, this Court declines to frame a question on this issue. AMP expenditure - it stands covered in favour of the Assessee and against the Revenue by order Principal Commissioner of Income Tax-4 v. Honda Siel Power Products L ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 730/2018 (delay) 1. For the reasons stated in the application, the delay of 12 days in re-filing the appeal is condoned and the application is disposed of. ITA No. 1384/2018 2. The Revenue is in appeal against an order dated 17th April, 2018 passed by the Income Tax Appellate Tribunal in ITA No. 1579/Del/2017 for the Assessment Year 2012-2013. 3. The Reven ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ard to creation of intangibles were carried out in India for which arm s length remuneration was not paid? 2.4 Whether the Ld. ITAT erred in deleting the transfer pricing adjustment on account of AMP expenditure by ignoring a fact that functions performed, assets used and risk assumed by the Assessee in creating market for its Associated Enterprise (AE) and development of value of brand ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... a Jha, learned counsel appearing for the Assessee, contends that all of the above questions stand answered in favour of the Assessee and against the Revenue by the orders of this Court for the earlier AYs. She has placed before the Court the relevant orders in this regard. 5. As regards the disallowance on account of payment of Royalty on sales made to AEs, reference is made to the order ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ioner of Income Tax v. Honda Siel Power Products Limited). 8. The issue concerning provision for warranty as an allowable expense is answered in favour of the Assessee and against the Revenue by the order dated 6th May, 2013 in ITA No. 474/2011 (CIT v. Honda Siel Cars India Limited). 9. Accordingly no substantial question of law arises. The appeal is dismissed. - - T ..... X X X X Extracts X X X X X X X X Extracts X X X X
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