TMI Blog2015 (11) TMI 1796X X X X Extracts X X X X X X X X Extracts X X X X ..... mpugned order - HAs regards the above three issues, the Court is satisfied that no substantial question of law arises. TP Adjustment - Transactional Net Margin Method (TNMM) to the resale price method (RPM) as the most appropriate method (MAM) for the purposes of determination of the arms length price (ALP) - HELD THAT:- The Court sees no reason to interfere since the adoption of the RPM by t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ITA No.1115/Del/2014 and 617/Del/2014 for the Assessment Year ( AY ) 2009-10. 4. Three of the questions urged by the Revenue in the present appeal concern the deletion of additions made by the Assessing Officer ( AO ) on account of (a) prior period expenses, (b) provisions for warranty expenses and (c) non deduction of TDS under Section 40(a)(ia) of the Income Tax Act, 1961 ( Act ). Pr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the judgement of this Court in Sony Ericsson Mobile Communications India Pvt. Ltd. vs. Commissioner of Income Tax-III (2015) 374 ITR 118 (Del) that issue already stands remanded to the ITAT by this Court by an order dated 20th May, 2015 in the Assessee s appeal (ITA No.336/2015) against the same impugned order of the ITAT. 7. Consequently, this appeal is disposed of by upholding the imp ..... X X X X Extracts X X X X X X X X Extracts X X X X
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