Thursday, 8 October 2015

ITAT directs TPO to compare AMP functions before making TP adjustment; follows Sony Ericsson's case

IT/ILT : It is mandatory to make a comparison of the AMP functions performed by the assessee and comparables and then make an adjustment, if any, due to differences between the two, so that the AMP functions performed by the assessee and comparable are brought to a similar platform going by the ratio laid down by the Delhi High Court in case of Sony Ericsson Mobile Communications India (P.) Ltd.

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