SONY INDIA PVT. LTD.,NEW DELHI vs. ACIT CIRCLE-24(1), NEW DELHI

ITA 9080/DEL/2019Status: DisposedITAT Delhi08 August 2025AY 2015-1634 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal decided to deal with the grounds of appeal as issues, with the first issue relating to substantive additions for AY 2015-16 and protective additions in all three AYs concerning alleged international transactions of AMP expenses based on the Bright Line Test (BLT).

What were the facts?

The assessee, Sony India Pvt. Ltd., appealed against assessment orders for AY 2015-16, 2017-18, and 2018-19. The appeals primarily concerned transfer pricing adjustments related to import of finished goods, marketing and development of market services (MMDS), royalty payments, and advisory services.

What were the issues?

The key issues revolve around transfer pricing adjustments, including the use of the Intensity approach and BLT for AMP expenses, and the disallowance of various expenses like stock valuation loss, CSR, royalty, and warranty provisions.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144C(13),Section 115JB,Section 271(1)(c)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCHES: H : NEW DELHI

Before: SHRI ANUBHAV SHARMA & SHRI MANISH AGARWAL

For Appellant: Shri Nageshwar Rao, Advocate &, Shri Parth, Advocate
For Respondent: Shri S.K. Jhadav, CIT-DR
Hearing: 02.07.2025Pronounced: 08.08.2025

Heard together (3 matters)

ITA No.9080/Del/2019
ITA No.1688/Del/2022
ITA No.2052/Del/2022

Read from the judgment's own cause title. This page is filed under one of them.

PER ANUBHAV SHARMA, JM:

These appeals are preferred by the Assessee against the final assessment orders dated 31.10.2019 and 30.06.2022 passed by the Asstt. Commissioner of Income Tax, Circle 24(1), Delhi and ACIT Circle-22(2), Delhi (hereinafter referred to as the Ld. AO) u/s 143(3) r.w.s.144C(13) of the Income Tax Act, 1961 (hereinafter referred as 'the Act') for the assessment years 2015-16 and 2017-18, respectively.

2.

Heard the ld. representatives of both the sides who have argued these appeals on the basis of facts and referring to

The order continues below.

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