Sony Ericsson Mobile Communications India Pvt. Ltd. v. CIT

374 ITR 118High Court2015#139 most cited

What is Sony Ericsson Mobile Communications India Pvt. Ltd. v. CIT authority for?

The existence of an international transaction for Advertising and Marketing Promotion (AMP) expenditure requires the revenue to discharge the burden of proof. An explanation inserted under Section 92B does not automatically make AMP expenditure an international transaction.

499

judgments rely on this decision, according to BharatTax’s citation analysis of 367,181 Indian tax judgments — from 2015 to 2026.

Also referred to as

Sony Ericsson Mobile Communications India Pvt. Ltd. v. CIT · 374 ITR 118 · Section 92B · AMP expenditure · international transaction · bright line test · burden of proof · revenue

Also reported as

2015 SCC OnLine DEL 8083

Sections most often in play

Section 143(3)Section 92BSection 144C(13)Section 92CSection 234BSection 14ASection 37Section 37(1)
Read the full judgment

Issues it is cited on

bright line testamp expendituresection 92ffunctional analysiscost plus methodtested partysection 92c(3)section 92btransactional net margin methodcup methodbenchmarking analysiscomparable companies

Judgments citing Sony Ericsson Mobile Communications India Pvt. Ltd. v. CIT

Addl. CIT, New Delhi vs. M/S. Swarovski India Pvt. Ltd., New Delhi

In the result, all the appeals of the assessee and the Revenue are allowed for statistical purpose

ITA 3417/DEL/2017[2007-08]Status: DisposedITAT Delhi25 Jul 2019AY 2007-08

Bench: Shri Pramod Kumar & Shri K. Narasimha Chary

For Appellant: S/Sh Kamal Sawhney &For Respondent: Shri Rakesh Kumar, Sr. DR
Section 143(3)Section 144CSection 92C

…f Assessment Year 2011-12, for analysing the AMP expenses wherein straightaway bright line was followed, without referring to the directions of the Hon’ble Delhi High Court in the case of Sony Ericsson Mobile Communications (India) Private Ltd vs. CIT [(2015) 374 ITR 118]. 8. In respect of Assessment Years2007-08 to 2009-10 and 2011-12, assessee is challenging the order of the Ld. CIT(A) in applying the same parameters of the Bright Line Test (BLT) stating that it has not a statutory mandate under the Act, whereas the Revenue is challenging the action of the Ld. CIT(A) in directing the use of RPM as the most appr…

Swaro vs. Ki India Pvt. Ltd., New Delhi

In the result, all the appeals of the assessee and the Revenue are allowed for statistical purpose

ITA 2578/DEL/2017[2008-09]Status: DisposedITAT Delhi25 Jul 2019AY 2008-09

Bench: Shri Pramod Kumar & Shri K. Narasimha Chary

For Appellant: S/Sh Kamal Sawhney &For Respondent: Shri Rakesh Kumar, Sr. DR
Section 143(3)Section 144CSection 92C

…f Assessment Year 2011-12, for analysing the AMP expenses wherein straightaway bright line was followed, without referring to the directions of the Hon’ble Delhi High Court in the case of Sony Ericsson Mobile Communications (India) Private Ltd vs. CIT [(2015) 374 ITR 118]. 8. In respect of Assessment Years2007-08 to 2009-10 and 2011-12, assessee is challenging the order of the Ld. CIT(A) in applying the same parameters of the Bright Line Test (BLT) stating that it has not a statutory mandate under the Act, whereas the Revenue is challenging the action of the Ld. CIT(A) in directing the use of RPM as the most appr…

Swaro vs. Ki India Pvt. Ltd., New Delhi

In the result, all the appeals of the assessee and the Revenue are allowed for statistical purpose

ITA 2577/DEL/2017[2007-08]Status: DisposedITAT Delhi25 Jul 2019AY 2007-08

Bench: Shri Pramod Kumar & Shri K. Narasimha Chary

For Appellant: S/Sh Kamal Sawhney &For Respondent: Shri Rakesh Kumar, Sr. DR
Section 143(3)Section 144CSection 92C

…f Assessment Year 2011-12, for analysing the AMP expenses wherein straightaway bright line was followed, without referring to the directions of the Hon’ble Delhi High Court in the case of Sony Ericsson Mobile Communications (India) Private Ltd vs. CIT [(2015) 374 ITR 118]. 8. In respect of Assessment Years2007-08 to 2009-10 and 2011-12, assessee is challenging the order of the Ld. CIT(A) in applying the same parameters of the Bright Line Test (BLT) stating that it has not a statutory mandate under the Act, whereas the Revenue is challenging the action of the Ld. CIT(A) in directing the use of RPM as the most appr…

Swaro vs. Ki India Pvt. Ltd., New Delhi

In the result, all the appeals of the assessee and the Revenue are allowed for statistical purpose

ITA 964/DEL/2016[2011-12]Status: DisposedITAT Delhi25 Jul 2019AY 2011-12

Bench: Shri Pramod Kumar & Shri K. Narasimha Chary

For Appellant: S/Sh Kamal Sawhney &For Respondent: Shri Rakesh Kumar, Sr. DR
Section 143(3)Section 144CSection 92C

…f Assessment Year 2011-12, for analysing the AMP expenses wherein straightaway bright line was followed, without referring to the directions of the Hon’ble Delhi High Court in the case of Sony Ericsson Mobile Communications (India) Private Ltd vs. CIT [(2015) 374 ITR 118]. 8. In respect of Assessment Years2007-08 to 2009-10 and 2011-12, assessee is challenging the order of the Ld. CIT(A) in applying the same parameters of the Bright Line Test (BLT) stating that it has not a statutory mandate under the Act, whereas the Revenue is challenging the action of the Ld. CIT(A) in directing the use of RPM as the most appr…

DCIT, Gurgaon vs. M/S. Bain & Company India Pvt. Ltd., Gurgaon

In the result, both the appeals of the Revenue and Cos preferred by the assessee are dismissed

ITA 379/DEL/2015[2009-10]Status: DisposedITAT Delhi25 Jul 2019AY 2009-10

Bench: Shri Pramod Kumar & Shri K. Narsimha Chary

For Appellant: Sh. Sandeep Kumar Mishtra, Sr.DRFor Respondent: Sh. Tarandeep Singh, Adv. &
Section 143(3)Section 92C

…essional techniques, consulting know- how etc. 10. Ld. AR placing reliance on the decision of the Hon’ble Delhi High Court in the case of AWB India private limited vs. CIT 166 TTJ 521 (Del) and Sony Ericsson mobile communications India private limited vs. CIT 374 ITR 118 (Del) in support of his submission argued that the question of payment of royalty cannot be determined on the basis of profitability or earnings of the assessee, once it is accepted that know-how and technical information was provided; that in the absence of any material to disprove that the impugned payments are made under the agreement with the…

Swaro vs. Ki India Pvt. Ltd., New Delhi

In the result, all the appeals of the assessee and the Revenue are allowed for statistical purpose

ITA 2579/DEL/2017[2009-10]Status: DisposedITAT Delhi25 Jul 2019AY 2009-10

Bench: Shri Pramod Kumar & Shri K. Narasimha Chary

For Appellant: S/Sh Kamal Sawhney &For Respondent: Shri Rakesh Kumar, Sr. DR
Section 143(3)Section 144CSection 92C

…f Assessment Year 2011-12, for analysing the AMP expenses wherein straightaway bright line was followed, without referring to the directions of the Hon’ble Delhi High Court in the case of Sony Ericsson Mobile Communications (India) Private Ltd vs. CIT [(2015) 374 ITR 118]. 8. In respect of Assessment Years2007-08 to 2009-10 and 2011-12, assessee is challenging the order of the Ld. CIT(A) in applying the same parameters of the Bright Line Test (BLT) stating that it has not a statutory mandate under the Act, whereas the Revenue is challenging the action of the Ld. CIT(A) in directing the use of RPM as the most appr…

ACIT, New Delhi vs. M/S. Swarovski India Pvt. Ltd., Gurgaon

In the result, all the appeals of the assessee and the Revenue are allowed for statistical purpose

ITA 1055/DEL/2016[2011-12]Status: DisposedITAT Delhi25 Jul 2019AY 2011-12

Bench: Shri Pramod Kumar & Shri K. Narasimha Chary

For Appellant: S/Sh Kamal Sawhney &For Respondent: Shri Rakesh Kumar, Sr. DR
Section 143(3)Section 144CSection 92C

…f Assessment Year 2011-12, for analysing the AMP expenses wherein straightaway bright line was followed, without referring to the directions of the Hon’ble Delhi High Court in the case of Sony Ericsson Mobile Communications (India) Private Ltd vs. CIT [(2015) 374 ITR 118]. 8. In respect of Assessment Years2007-08 to 2009-10 and 2011-12, assessee is challenging the order of the Ld. CIT(A) in applying the same parameters of the Bright Line Test (BLT) stating that it has not a statutory mandate under the Act, whereas the Revenue is challenging the action of the Ld. CIT(A) in directing the use of RPM as the most appr…

DCIT, Gurgaon vs. M/S. Bain & Company India Pvt. Ltd., Gurgaon

In the result, both the appeals of the Revenue and Cos preferred by the assessee are dismissed

ITA 378/DEL/2015[2008-09]Status: DisposedITAT Delhi25 Jul 2019AY 2008-09

Bench: Shri Pramod Kumar & Shri K. Narsimha Chary

For Appellant: Sh. Sandeep Kumar Mishtra, Sr.DRFor Respondent: Sh. Tarandeep Singh, Adv. &
Section 143(3)Section 92C

…essional techniques, consulting know- how etc. 10. Ld. AR placing reliance on the decision of the Hon’ble Delhi High Court in the case of AWB India private limited vs. CIT 166 TTJ 521 (Del) and Sony Ericsson mobile communications India private limited vs. CIT 374 ITR 118 (Del) in support of his submission argued that the question of payment of royalty cannot be determined on the basis of profitability or earnings of the assessee, once it is accepted that know-how and technical information was provided; that in the absence of any material to disprove that the impugned payments are made under the agreement with the…

India Medtronic P.Ltd, Mumbai vs. DCIT (OSD) 8(2), Mumbai

ITA 2168/MUM/2014[2009-10]Status: DisposedITAT Mumbai24 Jul 2019AY 2009-10

Bench: Shri G. Manjunatha & Shri Ravish Soodita No.2168/Mum/2014 & C.O. No. 213/Mum/2014 (Arising Out Of Ita No. 2121/Mum/2014) (Assessment Year: 2009-10) India Medtronic Private Ltd. Assistant Commissioner Of 1241, Solitaire Corporate Park, Income Tax, Circle-10(1)(1), Building No.12, 209, Aaykar Bhavan, Vs. 4Th Floor, Andheri Ghatkopar Churchgate, Link Road, Andheri (East), Mumbai –20 Mumbai 400 093 Pan – Aaaci4227Q (Appellant) (Respondent) Assistant Commissioner Of M/S India Medtronic Pvt. Ltd. Income Tax (Osd)-8(2), Solitaire Corporate Park, Room No. 218, Aayakar Bhavan, Bldg. No. 12, 4Th Floor, M.K. Marg, Vs. Andheri Ghatkopar Link Rd., Mumbai – 400020 Andheri (East), Mumbai- 400093

For Appellant: Shri Rajan R. Vora, A.RFor Respondent: Shri Anand Mohan, D.R
Section 115JSection 143(1)Section 143(2)Section 143(3)Section 144C(13)Section 254

…ed for to the method of benchmarking i.e TNMM that was adopted by the assessee. It was observed by the Tribunal that by virtue of the judgement of the Hon‟ble High Court of Delhi in the case of Sony Ericsson Mobile Communication India Pvt. ltd. Vs. CIT (2015) 374 ITR 118 (Del), the decision of the „Special Bench‟ of the Tribunal in the case of L.G. Electronics India Pvt. ltd. Vs. ACIT (2013) 152 TTJ 273 (Del) (SB) had been reversed on the issue as regards adoption of the “Bright Line Test” (for short “BLT”) for benchmarking the AMP transactions. However, as the order of the Hon‟ble High Court of Delhi in the case…

Pernod Ricard India Pvt. Ltd., New Delhi vs. DCIT, New Delhi

In the result, the recalled matter of the appeal in ITA No

ITA 914/DEL/2015[2011-12]Status: DisposedITAT Delhi10 Jul 2019AY 2011-12

Bench: Shri Amit Shukla & Shri O.P. Kant

Section 144C(13)Section 194HSection 40

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH: ‘I-1’, NEW DELHI BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER AND SHRI O.P. KANT, ACCOUNTANT MEMBER ITA Nos.910 to 914/Del/2015 Assessment Years:2007-08 to 2011-12 M/s. Pernod Ricard India Pvt. Vs. DCIT, Ltd. (Formerly known as Central Circle-31, New Delhi Seagram India Pvt. Ltd.), 104, Ashoka Estate, Barakhamba Road, New Delhi PAN :AAACS4781P (Appellant) (Respondent) Appellant by Sh. Deepak Chopra, Adv. Sh. Yujit Pareek, Adv.; and Ms. Rashi Khanna, Adv. Respondent by Sh. Sanjay I. Bara, CIT(DR) Date of hearing 01.07.2019 Date of pronouncement 10.07.2019 ORDER PER O.…

Pernod Ricard India Pvt. Ltd., New Delhi vs. DCIT, New Delhi

In the result, the recalled matter of the appeal in ITA No

ITA 912/DEL/2015[2009-10]Status: DisposedITAT Delhi10 Jul 2019AY 2009-10

Bench: Shri Amit Shukla & Shri O.P. Kant

Section 144C(13)Section 194HSection 40

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH: ‘I-1’, NEW DELHI BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER AND SHRI O.P. KANT, ACCOUNTANT MEMBER ITA Nos.910 to 914/Del/2015 Assessment Years:2007-08 to 2011-12 M/s. Pernod Ricard India Pvt. Vs. DCIT, Ltd. (Formerly known as Central Circle-31, New Delhi Seagram India Pvt. Ltd.), 104, Ashoka Estate, Barakhamba Road, New Delhi PAN :AAACS4781P (Appellant) (Respondent) Appellant by Sh. Deepak Chopra, Adv. Sh. Yujit Pareek, Adv.; and Ms. Rashi Khanna, Adv. Respondent by Sh. Sanjay I. Bara, CIT(DR) Date of hearing 01.07.2019 Date of pronouncement 10.07.2019 ORDER PER O.…

Pernod Ricard India Pvt. Ltd., New Delhi vs. DCIT, New Delhi

In the result, the recalled matter of the appeal in ITA No

ITA 911/DEL/2015[2008-09]Status: DisposedITAT Delhi10 Jul 2019AY 2008-09

Bench: Shri Amit Shukla & Shri O.P. Kant

Section 144C(13)Section 194HSection 40

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH: ‘I-1’, NEW DELHI BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER AND SHRI O.P. KANT, ACCOUNTANT MEMBER ITA Nos.910 to 914/Del/2015 Assessment Years:2007-08 to 2011-12 M/s. Pernod Ricard India Pvt. Vs. DCIT, Ltd. (Formerly known as Central Circle-31, New Delhi Seagram India Pvt. Ltd.), 104, Ashoka Estate, Barakhamba Road, New Delhi PAN :AAACS4781P (Appellant) (Respondent) Appellant by Sh. Deepak Chopra, Adv. Sh. Yujit Pareek, Adv.; and Ms. Rashi Khanna, Adv. Respondent by Sh. Sanjay I. Bara, CIT(DR) Date of hearing 01.07.2019 Date of pronouncement 10.07.2019 ORDER PER O.…

Aircom International (India) Pvt. Ltd., New Delhi vs. DCIT, Circle- 2(1), New Delhi

In the result, these grounds raised by assessee stands allowed for statistical purposes

ITA 7682/DEL/2017[2013-14]Status: DisposedITAT Delhi20 Jun 2019AY 2013-14

Bench: Shri N.S. Saini & Smt. Beena A Pillaiay: 2012-13 & Ay: 2013-14

For Appellant: Sh. Salil Kapur, AdvFor Respondent: Sh. Sanjay I Bara, CIT, D.R
Section 40A(2)(a)Section 92C

…portionately apportioned amongst 4 segments, which Ld.TPO accepted while analysing arm’s length price of individual segments. He further relying on decision of Hon’ble Delhi High Court in case of Sony Ericson Mobile Communications India Pvt. Ltd., reported in 374 ITR 118, submitted that segregation cannot be made as they are interlinked with each other. 13.2. He submitted that management fees paid by assessee to its AEs are for support provided by AE under each segment and therefore they are interlinked with each other. Ld.Counsel thus submitted that, as transaction have been held to be at arm’s length price by L…

Aircom International (India) Pvt. Ltd., New Delhi vs. ACIT, New Delhi

In the result, these grounds raised by assessee stands allowed for statistical purposes

ITA 1956/DEL/2017[2012-13]Status: DisposedITAT Delhi20 Jun 2019AY 2012-13

Bench: Shri N.S. Saini & Smt. Beena A Pillaiay: 2012-13 & Ay: 2013-14

For Appellant: Sh. Salil Kapur, AdvFor Respondent: Sh. Sanjay I Bara, CIT, D.R
Section 40A(2)(a)Section 92C

…portionately apportioned amongst 4 segments, which Ld.TPO accepted while analysing arm’s length price of individual segments. He further relying on decision of Hon’ble Delhi High Court in case of Sony Ericson Mobile Communications India Pvt. Ltd., reported in 374 ITR 118, submitted that segregation cannot be made as they are interlinked with each other. 13.2. He submitted that management fees paid by assessee to its AEs are for support provided by AE under each segment and therefore they are interlinked with each other. Ld.Counsel thus submitted that, as transaction have been held to be at arm’s length price by L…

M/S Bmw India Pvt. Ltd., Gurgaon vs. DCIT, Gurgaon

In the result ground number 7 – 12 of the appeal of the assessee are allowed accordingly

ITA 1163/DEL/2017[2012-13]Status: DisposedITAT Delhi14 Jun 2019AY 2012-13

Bench: Shri Kuldip Singh & Shri Prashant Maharishibmw India Pvt. Ltd, Vs. Dcit, 7Th Floor, Tower-B, Building No. Circle-1(1), 8, Gurgaon Gurgaon Pan: Aabcb7104C (Appellant) (Respondent)

For Appellant: Shri Percy Pardiwala, Sr. AdvFor Respondent: Shri H. K. Choudhary, CIT DR
Section 143Section 144CSection 92BSection 92p

…dispute that the TPO has made adjustment applying BLT which was enhanced by DRP though for a different reason. 13 29. At the outset, we have to state that the Hon‟ble High Court of Delhi in the case of Sony Ericsson Mobile Communications India Pvt Ltd vs CIT 374 ITR 118 has discarded the BLT. The Hon‟ble High Court, at para 120 held as under: “120. Notwithstanding the above position, the argument of the Revenue goes beyond adequate and fair compensation and the ratio of the majority decision mandates that in each case where an Indian subsidiary of a foreign AE incurs AMP expenditure should be subjected to the br…

Zimmer India Private Ltd, Gurgaon vs. DCIT, Gurgaon

The appeal of the assessee are dismissed

ITA 6804/DEL/2015[2011-12]Status: DisposedITAT Delhi14 Jun 2019AY 2011-12

Bench: Shri Kuldip Singh & Shri Prashant Maharishizimmer India Private Ltd, Dcit, Vs. 14Th Floor, Tower-B, Dlf Circle-4(1), Building No. 05, Cyber City, Gurgaon Phase-Iii, Gurgaon Pan: Aaecs7432H (Appellant) (Respondent)

For Appellant: Shri Manoneet Dalal, AdvFor Respondent: Shri H. K. Choudhary, CIT DR
Section 143(3)Section 144C(13)Section 92Section 92C

…its benchmarking and determination of ALP does not arise. At the very outset, the ld. AR stated that Bright Line Test adopted by the TPO has been discarded by the Hon'ble Delhi High Court in the case of Sony Ericsson Mobile Communications India Pvt Ltd vs CIT 374 ITR 118 = 2015-TII-06- HC-DEL-TP. Nowhere the TPO has brought any tangible material on record to show that there exists an international transaction in so far as AMP spend is concerned. In support of his contention, the ld. AR relied upon the decision of the Hon'ble High Court of Delhi in the case of Maruti Suzuki India Ltd 381 ITR 117 = 2015-TII-58-HC-D…

Toshiba India Pvt. Ltd., Gurgaon vs. DCIT, Circle- 25(2), New Delhi

In the result, appeal of the revenue is allowed in part and the appeal of the assessee is allowed

ITA 7340/DEL/2018[2011-12]Status: DisposedITAT Delhi11 Jun 2019AY 2011-12

Bench: Shri. N. S. Saini & Shri K. Narasimha Chary

For Appellant: Shri Nageshwar Rao, AdvocateFor Respondent: Shri H.K.Choudhary, CIT DR
Section 90

…s common order. 7. Insofar as the adjustment on protective basis following the BLT is concerned, at the outset, Ld. AR brought to our notice that the Hon’ble jurisdictional High Court in the case of Sony Ericsson Mobile Communications Private Limited vs. CIT 374 ITR 118 invalidated the application of BLT for making any adjustment in respect of AMP. He further submitted that in assessee’s own case for the assessment year 2009-10 and assessment year 2014-15, a coordinate Bench of this Tribunal in ITA No. 1438/del/2018 and ITA No. 7547/del/2018 respectively by orders dated 18/6/2018 and 10/1/2019 respectively delet…

DCIT, New Delhi vs. M/S Toshiba India Pvt. Ltd., Gurgaon

In the result, appeal of the revenue is allowed in part and the appeal of the assessee is allowed

ITA 1611/DEL/2016[2011-12]Status: DisposedITAT Delhi11 Jun 2019AY 2011-12

Bench: Shri. N. S. Saini & Shri K. Narasimha Chary

For Appellant: Shri Nageshwar Rao, AdvocateFor Respondent: Shri H.K.Choudhary, CIT DR
Section 90

…s common order. 7. Insofar as the adjustment on protective basis following the BLT is concerned, at the outset, Ld. AR brought to our notice that the Hon’ble jurisdictional High Court in the case of Sony Ericsson Mobile Communications Private Limited vs. CIT 374 ITR 118 invalidated the application of BLT for making any adjustment in respect of AMP. He further submitted that in assessee’s own case for the assessment year 2009-10 and assessment year 2014-15, a coordinate Bench of this Tribunal in ITA No. 1438/del/2018 and ITA No. 7547/del/2018 respectively by orders dated 18/6/2018 and 10/1/2019 respectively delet…

Qualcom India Pvt. Ltd., New Delhi vs. DCIT, New Delhi

In the result appeal filed by assessee stands allowed for statistical purposes

ITA 1810/DEL/2014[2009-10]Status: DisposedITAT Delhi03 Jun 2019AY 2009-10

Bench: Shri N.S. Saini & Smt. Beena A Pillaiay: 2009-10

For Appellant: Sh. Naveen K. Aggarwal &For Respondent: Sh. Sanjay I Bara, CIT, DR
Section 10ASection 92C(3)

…he segregation of these two transactions of payment of Royalty and Fees for technical services from the other international transaction, is justified? 5.3 The Hon'ble jurisdictional High Court in Sony Ericson Mobile Communication India (P.) Ltd. v. CIT [2015] 374 ITR 118/231 Taxman 113/55 taxmann.com 240 (Delhi), has dealt with the circumstances in which aggregation can be done in the context of AMP expenses. The principles laid down in this case are universally applicable and are not confined to the peculiar facts of that case alone. It has been held that 'transactions includes the number of closely linked trans…

Videojet Technologies (I) P. Ltd, Navi Mumbai vs. Asst CIT Cir 10(3), Mumbai

In the result, appeal of the assessee is allowed

ITA 6956/MUM/2012[2008-09]Status: DisposedITAT Mumbai28 May 2019AY 2008-09

Bench: Shri G.S.Pannu & Shri Ravish Soodm/S Videojet Technologies Vs. Acit, Circle-10(3), Mumbai (I) Pvt. Limited, Unit 101 & 102, Rupa Solitaire, Building No.A-1, Sector-1, Millennium Business Park, Mahape, Navi Mumbai-400710 Pan No.Aaacw0731 B (Appellant) .. (Respondent)

Section 143(3)Section 92C(2)

…of this Court in its decision in Bausch & Lomb Eyecare (India) (P.) Ltd. v. Addl. CIT[2016] 381 ITR 227/237 Taxman 24/65 taxmann.com 141 (Delhi), while considering the decision of this Court in Sony Ericsson Mobile Communications India (P.) Ltd. v. CIT[2015] 374 ITR 118/231 Taxman 113/55 taxmann.com 240 (Delhi), noted that: "The RP Method loses its accuracy and reliability where the reseller adds substantially to the value of the product or the goods are further processed or incorporated into a more sophisticated product or when the product/service is transformed." 12. Therefore, a contrario, when the reseller d…