Dismissing the appeal of the revenue, the Court held that, where no ALP adjustment was made by the TPO, a separate AMP adjustment was uncalled for. Order of Tribunal affirmed. (AY. 2010-11)
PCIT v. Sony India (P.) Ltd. (2025) 307 Taxman 173 (Delhi)(HC)
S. 92C: Transfer pricing-Arm’s length price-Distribution business-No ALP adjustment made by TPO-Separate AMP adjustment was uncalled for-Order of Tribunal affirmed. [S. 260A ]
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