SANJIV KHANNA, V.KAMESWAR RAO
Sony Ericsson Mobile Communications India (P. ) Ltd. – Appellant
Versus
Commissioner of Income-tax –III – Respondent
Sanjiv Khanna, J.
1. This common judgment will dispose of these appeals and cross-appeals by the assessee and the Revenue in which one of the primary issue that emanates for consideration is whether advertisement, marketing and sale promotion expenditure ('AMP', for short) beyond and exceeding the 'bright line' is a separate and independent international transaction undertaken by the resident Indian assessee towards brand building for the brand owner, i.e. the foreign Associated Enterprise ('AE', for short). Other core issues pertain to aspects of arm's length pricing of international transactions.
2. The details of appeals and cross-appeals by the assessees and the Revenue and the assessment years involved are as under:
Assessment year
ITA No.
Assessee
Cross Appeal by Revenue
2008-09
16/2014
Sony Ericsson Mobile Communications India Pvt. Ltd/Sony Mobile Communication India Pvt. Ltd. Now known as, Sony India Ltd.
155/2014
2008-09
70/2014
Discovery Communications India
218/2014
2006-07
521/2013
Canon India Pvt. Ltd.
132/2
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