How many judgments cite Sony India (P) Ltd. v. DCIT?

131 judgments on BharatTax cite Sony India (P) Ltd. v. DCIT (114 ITD 448), spanning 2015 to 2025.

Which sections of the Income Tax Act does Sony India (P) Ltd. v. DCIT come up under?

It is most often cited in judgments turning on Section 143(3), Section 133(6), Section 147, Section 148, Section 14A, Section 151.

Sony India (P) Ltd. v. DCIT

114 ITD 448Income Tax Appellate Tribunal2008#783 most cited

What is Sony India (P) Ltd. v. DCIT authority for?

For transfer pricing purposes, functionally dissimilar entities that have significant business differences must be excluded from the list of comparables for benchmarking analysis. It also provides guidance on the non-allocation of advertisement, marketing, and promotion (AMP) expenses to other entities when incurred solely for the assessee's business.

131

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2015 to 2025.

Also referred to as

Sony India (P) Ltd. v. DCIT · 114 ITD 448 · transfer pricing · comparables exclusion · functional dissimilarity · benchmarking analysis · AMP expenses · allocation of AMP expenditure · section 92BA · working capital adjustment · section 37(1) · associated enterprises

Also reported as

118 TTJ 865

Sections most often in play

Section 143(3)Section 133(6)Section 147 Section 148 Section 14A Section 151 Section 37(1)Section 80IC

Issues it is cited on

amp expenditure section 92ba true and full disclosure captive service provider sanction under section 151 transfer pricing order working capital adjustment fresh tangible material section 148(2)sanctioning authority specified domestic transaction tested party

Judgments citing Sony India (P) Ltd. v. DCIT

Cameron Manufacturing India Pvt Ltd, Coimbatore vs. DCIT, Corporate Circle-1, Coimbatore

In the result appeal of the assessee is partly allowed for statistical purposes as indicated herein above

ITA 336/CHNY/2018[2013-14]Status: DisposedITAT Chennai16 Oct 2018AY 2013-14

Bench: Shri A.Mohan Alankamony & Shri Duvvuru Rl Reddyआयकर अपील सं./I.T.A.No.336/Chny/2018 (िनधा"रण वष" / Assessment Year: 2013-14) Vs The Dcit, M/S. Cameron Manufacturing India Pvt. Ltd., Corporate Circle-1, Tidel Park, Vilankurichi Road, Coimbatore. Civil Aerodrome Post, Coimbatore – 641 014. Pan: Aabcn2803J (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri M. Srinivasa Rao, CIT

Section 115JSection 143(2)Section 143(3)Section 92C

…03.2017. (ii) Order of the Chennai Bench of the Tribunal in the case of M/s. Lason India Pvt. Ltd., in ITA No.1026/Mds/2014 vide order dated 27.05.2016. (iii) Order of the Delhi Bench of the Tribunal in the case of M/s. Sony India (P) Ltd., reported in [2008] 114 ITD 448 vide order dated 23.09.2008. (iv) Order of the Bangalore Bench of the Tribunal in the case of M/s. Supportsoft India Pvt. Ltd., in IT(TP)A No.1372/Bang/2011 & IT(TP)A No.20/Bang/2012 vide order dated 28.03.2017. (v) Order of the Bangalore Bench of the Tribunal in the case of. M/s. Bearing Point Business Consulting (P) Ltd., in ITA No.1124/Bang/20…

Starent Networks (India) Private Limited, Pune vs. Joint Commissioner of Income-Tax

In the result, appeal of assessee is partly allowed

ITA 585/PUN/2014[2009-10]Status: DisposedITAT Pune26 Sept 2018AY 2009-10

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.585/Pun/2014 यििाारण वषा / Assessment Year : 2009-10

For Appellant: Shri Rajendra AgiwalFor Respondent: Smt. Nirupama Kotru and Shri S.B. Prasad

Section 10ASection 143(3)Section 253(1)Section 92C(2)

…ssee’s own case relating to assessment year 09.02.2018 in paras 34 to 36 allowed the issue in respect of economic adjustment in the hands of assessee, following the ratio laid down by the Delhi Bench of Tribunal in the case of Sony India Pvt. Ltd. reported in 114 ITD 448. The relevant findings are in paras 34 to 36 of the order of Tribunal, dated 14 09.02.2018 which are being referred to but are not being reproduced for the sake of brevity. Following the same parity of reasoning, we direct the Assessing Officer to allow adjustment on account of risk difference in the hands of assessee and the comparables finally…

St- Ericsson India Pvt. Ltd., New Delhi vs. DCIT, Circle-24(2), New Delhi

In the result, the appeal filed by the assessee in ITA No

ITA 4434/DEL/2018[2013-14]Status: DisposedITAT Delhi26 Sept 2018AY 2013-14

Bench: Shri N.K. Billaiya & Shri Sudhanshu Srivastava[A.Y 2013-14] St-Ericsson India Pvt. Ltd Vs. The Dy.C.I.T S-327, Lower Ground Floor Circle – 24(2) Greater Kailash – Ii, New Delhi New Delhi Pan : Aamcs 1022 K [Appellant] [Respondent]

For Appellant: Shri S.D. Kapila, AdvFor Respondent: Shri H.K. Choudhary, CIT-DR

Section 143(3)Section 271Section 92C

…n each comparable as has been held by the coordinate Bench 'A', Pune Bench of the Tribunal in case of Honeywell Turbo Technologies (India) Pvt. Ltd. vs. DCIT in ITA No.2584/PUN/2012 order dated 10.02.2017 by following the case of Sony India Pvt. Ltd. cited as 114 ITD 448 by making following observation:- "33. Further, the Delhi Bench of Tribunal in the case of Sony India Pvt. Ltd. reported in 114 ITD 448 has allowed 20% risk adjustment considering the fact that it may not 27 (supra) has worked out the risk adjustment on the operating margins of comparables to be allowed when computed @ 20%. We direct the Assessin…

DCIT, New Delhi vs. M/S. Imsofer Manufacturing India Pvt. Ltd., Pune

In the result, the department’s appeal stands dismissed

ITA 5155/DEL/2015[2009-10]Status: DisposedITAT Delhi14 Aug 2018AY 2009-10

Bench: Sh. N.K.Saini & Sh. Sudhanshu Srivastava

For Respondent: Sh. Kumar Paranav, Sr. DR

…e in TNMM. Allowability of working capital adjustment has been upheld by the various Benches of the ITAT. ITAT Delhi has held working capital adjustment to be allowable in the cases of Mentor Graphics reported in 109 ITD 101 (Del) and Sony India reported in 114 ITD 448 (Del). Therefore, in view of the settled judicial precedents and further in view of the fact that the Ld. Sr. DR could not point out any legal infirmity in the direction of the Ld. CIT (A) for allowing working capital adjustment, we are unable to agree to the contentions of the Ld. Sr. DR and we find no reason to interfere with the findings o…

Bothra Shipping Services(Currently Known As Bothra Shipping Services (P) Ltd., Kolkata vs. ACIT, Cental Circle-1(1), Kolkata

In the result ground no. 11 & 12 are allowed for statistical purpose

ITA 178/KOL/2017[2010-2011]Status: DisposedITAT Kolkata31 Jul 2018AY 2010-2011

Bench: Sri J. Sudhakar Reddy & Sri Aby T. Varkey) Assessment Year: 2010-11 Assessment Year: 2011-12 Assessment Year: 2012-13 Bothra Shipping Services ......…..…….……………………..…………………………………..……….……..Appellant (Currently Known As Bothra Shipping Services Pvt. Ltd.) Room No. 10 2Nd Floor “Sagar Estate 2 Clive Ghat Street Kolkata – 700 107 [Pan : Aadfb 8479 P] Assistant Commissioner Of Income Tax, Central Circle-1(1), Kolkata.…….......….......Respondent Appearances By: Shri Naresh Jain & Mrs. Arati Debnath, Ar, Appeared On Behalf Of The Assessee. Shri G. Mallikarjuna, Cit, D/R. Appearing On Behalf Of The Revenue. Date Of Concluding The Hearing : June 26Th, 2018 Date Of Pronouncing The Order : July 31St , 2018 Order Per J. Sudhakar Reddy, Am :- All These Appeals Filed By The Assessee Are Directed Against The Separate Orders Passed U/S 144C R.W.S. 143(3) Of The Income Tax Act, 1961 (In Short The ‘Act’). As The Issues Arising In All These Appeals Are Common, For The Sake Of Convenience They Are Heard Together & Disposed Off By Way Of This Common Order. 2. Brief Facts Of This Case Are Brought Out By The Ld. Drp At Page 1 Of His Order Which Is Extracted For Ready Reference:- Bothra India Is Engaged In The Business Of Handling Bulk Cargoes. Its Activities Include Vessel Handling, Stevedoring & Cargo Handling, Clearing & Forwarding & Other Port Related Activities. Jaldhi Overseas Pte Ltd ('Jaldhi Overseas') Engages Bothra India For Vessel Handling At The Port, To Provide Various Vessel Related Services Until The Vessel

Section 143(3)Section 144CSection 153ASection 153BSection 92CSection 92C(3)

…arded to be comparable to the Assessee company and accordingly, we do not find any infirmity in the finding of CIT (A) while he excluded this company on the turnover criteria following the decision of this tribunal in : Sony India (P.) Ltd. v. Dy. CIT [2008] 114 ITD 448 (Delhi) E-Gain Communication (P.) Ltd. v. ITO [2008] 23 SOT 385 (Pune) Deloittee Consulting India (P.) Ltd. v. Dy. CIT [2013] 144 ITD 451/36 taxmann.com 68 (Hyd.) Genisys Integrating System (India) (P.) Ltd. v. Dy. CIT [2012] 53 SOT 159/20 taxmann.com 715 (Bang.) 6. The said findings of the Tribunal in respect of the said three Companies are on t…

Keane Worldzen India (Pvt.) Ltd., Gurgaon vs. ITO, New Delhi

In the result this ground raised by assessee stands allowed for statistical purposes

ITA 5339/DEL/2011[2007-08]Status: DisposedITAT Delhi12 Jul 2018AY 2007-08

Bench: Shri P.M.Jagtap & Smt. Beena A Pillaiay: 2007-08 Ntt Data Global Delivery Vs. Ito, Ward 5(2) Services Ltd. New Delhi (Formerly Known As Keane Worldzen (I) Pvt.Ltd.) Splendor Trade Tower 2Nd, 3Rd, 4Th, 5Th, 6Th & 7Th Floor Golf Course Extension Road Sector 65, Village Tigra Gurgaon Haryana 122 001 Pan: Aaacw3622M (Appellant) (Respondent) Assessee By : Sh. S.D.Kapila, Adv. Department By : Sh. Sanjay Kumar Yadav, Sr.Dr Date Of Hearing : 26.04.2018 Date Of Pronouncement: 12.07.2018

For Appellant: Sh. S.D.Kapila, AdvFor Respondent: Sh. Sanjay Kumar Yadav, Sr.DR

Section 143(2)Section 143(3)Section 144CSection 92C(2)

…sis of records placed before us. It is seen that the assessee had not raised this particular issue before DRP and is agitating for first time before us. Much reliance has been placed on the decision of ITAT Delhi Bench in Sony India (P.) Ltd v. Dy. CIT [2008] 114 ITD 448 wherein it has been held that there is no justification for excluding provisions written back in the Profit and Loss account as not forming part of the operating profit of the tax payer. 8.1. In the interest of justice, we restore the issue of writing back of provision for doubtful debts to be verified and treated as operating expense by the Ld.T…

DCIT, Noida vs. M/S. Adobe System India Pvt. Ltd., Noida

In the result, the appeals filed by the assessee as well as the Revenue are

ITA 6287/DEL/2015[2011-12]Status: DisposedITAT Delhi06 Jul 2018AY 2011-12

Bench: Shri R. K. Panda & Shri Kuldip Singhassessment Year : 2011-12 Adobe Systems India Pvt. Ltd., Acit, Circle- 1, Plot No.A5, Sector 132, Noida. Vs. Noida.

Section 10ASection 154Section 92C

…o be treated as part of the operating margins. While doing so, the ld. DRP relied on the decision of the Delhi Bench of the Tribunal in the case of First Rain Software Centre Private Limited (ITA No.4006/Del/2010) and Sony India Private Limited reported in 114 ITD 448. We do not find any infirmity in the order of the DRP on this issue. So far as bank charges are concerned, it has been held in various decisions that bank and finance charges are part of the operating expenses and should be treated as such in arriving at the margin. The Delhi Bench of the Tribunal in the case of Cash Edge India Pvt. Ltd. vide ITA…

M/S Adobe Systems India Pvt. Ltd., Noida vs. ACIT, Noida

In the result, the appeals filed by the assessee as well as the Revenue are

ITA 6165/DEL/2015[2011-12]Status: DisposedITAT Delhi06 Jul 2018AY 2011-12

Bench: Shri R. K. Panda & Shri Kuldip Singhassessment Year : 2011-12 Adobe Systems India Pvt. Ltd., Acit, Circle- 1, Plot No.A5, Sector 132, Noida. Vs. Noida.

Section 10ASection 154Section 92C

The Pr. Commissioner of Income Tax CIT (A) vs. M/S. Capco It Services Pvt Ltd

ITA/481/2017HC Karnataka05 Jul 2018

Bench: S.SUJATHA,VINEET KOTHARI

Section 10ASection 260

…comparability economic adjustments are also mandated by the Tribunal. Date of Judgment 05-07-2018 I.T.A.No.481/2017 The Pr. Commissioner of Income-Tax, CIT (A) & Anr. Vs. M/s. Capco IT Services Pvt. Ltd., 11/15 Sony India (P) Limited [114 ITD 448] E-Gain Communication Pvt. Ltd [118 ITD 243] Mentor Ruling Motorola Solutions India Private Limited Vs. ACIT [ITA No.5637/Del/2011] 15. Further, in addition to the above rulings the principle has also been upheld by the recent High Court ruling the case of Chryscapital Investment Advisors (India) Pvt. Ltd. Vs DCIT [ITA 41…

DCIT, Cir-6(1), Kolkata vs. M/S. Industrial Investment Bank of India, Kolkata

In the result, the appeals of the revenue are partly allowed for statistical purposes

ITA 894/KOL/2017[2012-13]Status: DisposedITAT Kolkata04 Jul 2018AY 2012-13

Bench: Hon’Ble Shri S.S. Godara, Jm & Hon’Ble Shri M.Balaganesh, Am] I.T.A Nos. 1870, 1871 & 894/Kol/2017 Assessment Years : 2010-11, 2011-12 & 2012-13 Dcit, Circle-6(1), Kolkata -Vs- M/S Industrial Investment Bank Of India [Pan: Aabci 0324 D] (Appellant) (Respondent)

For Appellant: Shri Md. Usman, CIT(DR)For Respondent: Shri Sanjay Bhattacharya, FCA

Section 143(2)Section 143(3)Section 44A

…o draw support from the following decisions :- a) Hon’ble Delhi High Court in the case of CIT vs Jagatjit Industries Ltd reported in (2011) 339 ITR 382 (Del) b) Co-ordinate Bench of Delhi Tribunal in the case of Sony India (P) Ltd vs DCIT reported in (2008) 118 TTJ 865 (Del Trib) c) Hon’ble Delhi High Court in the case of CIT vs Modipon Ltd reported in 334 ITR 102 (Del) d)Co-ordinate Bench of this Tribunal in the case of Hindustan Gum & Chemicals Ltd vs ITO reported in 23 SOT 143 for Asst Year 2003-04 4.4. In view of the aforesaid findings in the facts and circumstances of the case and respectfully following…

DCIT, Cir-6(1), Kolkata vs. M/S. Industrial Investment Bank of India, Kolkata

In the result, the appeals of the revenue are partly allowed for statistical purposes

ITA 1871/KOL/2017[2011-12]Status: DisposedITAT Kolkata04 Jul 2018AY 2011-12

For Appellant: Shri Md. Usman, CIT(DR)For Respondent: Shri Sanjay Bhattacharya, FCA

Section 143(2)Section 143(3)Section 44A

DCIT, Cir-6(1), Kolkata vs. M/S. Industrial Investment Bank of India, Kolkata

In the result, the appeals of the revenue are partly allowed for statistical purposes

ITA 1870/KOL/2017[2010-11]Status: DisposedITAT Kolkata04 Jul 2018AY 2010-11

For Appellant: Shri Md. Usman, CIT(DR)For Respondent: Shri Sanjay Bhattacharya, FCA

Section 143(2)Section 143(3)Section 44A

St- Ericsson India Pvt. Ltd., New Delhi vs. DCIT, New Delhi

ITA 609/DEL/2015[2010-11]Status: DisposedITAT Delhi03 Jul 2018AY 2010-11

Bench: Shri Chandra Poojari & Shri Kuldip Singh

For Appellant: Shri S.D. Kapila, AdvocateFor Respondent: Shri Sanjay Kumar Yadav, Senior DR

Section 143Section 144C

…n each comparable as has been held by the coordinate Bench ‘A’, Pune Bench of the Tribunal in case of Honeywell Turbo Technologies (India) Pvt. Ltd. vs. DCIT in ITA No.2584/PUN/2012 order dated 10.02.2017 by following the case of Sony India Pvt. Ltd. cited as 114 ITD 448 by making following observation:- “33. Further, the Delhi Bench of Tribunal in the case of Sony India Pvt. Ltd. reported in 114 ITD 448 has allowed 20% risk adjustment considering the fact that it may not be possible to quantify risk adjustments. The assessee applying the said ratio in the case of Sony India Pvt. Ltd. (supra) has worked out the r…

DCIT, New Delhi vs. M/S. St Ericsson India Pvt. Ltd., New Delhi

ITA 168/DEL/2015[2010-11]Status: DisposedITAT Delhi03 Jul 2018AY 2010-11

Bench: Shri Chandra Poojari & Shri Kuldip Singh

For Appellant: Shri S.D. Kapila, AdvocateFor Respondent: Shri Sanjay Kumar Yadav, Senior DR

Section 143Section 144C

The Pr. Commissioner of Income Tax, CIT(A) vs. M/S Ids Software Solutions India Pvt. Ltd

ITA/498/2017HC Karnataka02 Jul 2018

Bench: S.SUJATHA,VINEET KOTHARI

Section 10ASection 260

…mark up on the cost earn steady return year on year. In this regard, the Appellant would like to place reliance on the following Tribunal judgments, wherein comparability/ economic adjustments are also mandated by the Tribunal: Sony India [P] Limited [114 ITD 448] E-Gain Communication Pvt. Ltd., [118 ITD 243] Mentor Ruling Motorola Solutions India Private Limited V/s. ACIT [ITA No.5637/Del/2011] Further, in addition to the above rulings, the principle has also been upheld by the recent High Court ruling in the case of Chryscapital Date of Judgment 02-07-2018, ITA No.498/2017 The…

M/S. Exxonmobil Gas (India) Private Limited, New Delhi vs. DCIT, New Delhi

The appeal of the assessee is allowed for statistical purposes only

ITA 2702/DEL/2014[2009-10]Status: DisposedITAT Delhi26 Jun 2018AY 2009-10

Bench: Shri Joginder Singh & Shri R. K. Pandaassessment Year : 2009-10 Exxonmobil Gas (India) Private Dcit, Limited, Circle-11(1), Vs. 11033, Lane No.3, Doriwalan, Room No.405, C.R. Building, New Delhi Karol Bagh, Delhi-110005

For Respondent: Shri H. K. Choudhary, CIT-DR

Section 144C(5)

…urred by it in relation to providing business support services and also on a markup basis. The Ld. CIT-DR defended the addition. In reply, the ld. Counsel for the assessee, placed reliance upon the decisions in the case of Sony India Pvt. Ltd. vs DCIT (2008) 114 ITD 448 (Del.), Philips Software Centre Pvt. Ltd. vs ACIT (2008) 119 TTJ 721 (Bangalore), Mentorgraphics (Noida)(P.) Ltd. vs CIT (2007) 109 ITD 101(Del.), Kodiak Networks India Pvt. Ltd. vs ACIT (2012) 52 SOT 189 (Bangalore) and E-Gain Communications Pvt. Ltd. 118 TTJ 354 (Pune). 4. If the observation made in the assessment order, conclusion drawn b…

Efacec Switchgear India Pvt. Ltd., New Delhi vs. DCIT, Circle- 8(1), New Delhi

The appeal of the assessee is partly allowed for statistical purpose

ITA 7817/DEL/2017[2013-14]Status: DisposedITAT Delhi13 Jun 2018AY 2013-14

Bench: Shri N. K. Saini & Ms Suchitra Kambleefacec Switchgear India Pvt. Ltd. Vs Dcit 4Th Floor, Rectangle-1, Commercial Circle-8(1) Complex, D-4, District Centre, Saket, C. R. Building, I. P. Estate, New Delhi Aacce0747K New Delhi (Appelant) (Respondent)

Section 142(1)Section 143Section 143(2)Section 144CSection 271(1)Section 92C

…form part of the operational income because these items have nothing to do with the main operations of the assessee.” In support of the fact that amount written back is operations income, the Ld. AR relied upon the case of Sony India (P.) Ltd. vs. DCIT [2008] 114 ITD 448 (Delhi Trib.) para 106.02 of order. The Tribunal in this case has also relied upon the case of CIT v. S. Teja Singh [1959] 35ITR 408 (SC) where it was held that, “.... Having regard to statutory provisions, it cannot be said that provisions or writing back of liability is not .part of operating profit or would not be taken into consideration for…

Aptara Technologies Private Limited, Pune vs. Deputy Commissioner of Income-Tax

In the result, appeal of assessee is partly allowed

ITA 291/PUN/2016[2011-12]Status: DisposedITAT Pune05 Jun 2018AY 2011-12

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.291/Pun/2016 नििाारण वषा / Assessment Year : 2011-12 Aptara Technologies Private Limited, (Formerly: Maximize Learning Private Limited) F. No. A/16, Garnet Residency, S. No.9/13, Wanawadi, Pune- 411 040. Pan : Aaacc7416K .......अऩीऱाथी / Appellant बिाम / V/S. The Deputy Commissioner Of Income Tax, Circle -1(1), Pune. ……प्रत्यथी / Respondent

For Appellant: Shri Ketan K. VedFor Respondent: Shri Rajeev Kumar, CIT

Section 143(3)Section 234BSection 271(1)(c)Section 92C(2)

…further stated that the assessee had furnished the working as per the decision of Bangalore Bench of Tribunal in Philips Software Centre Pvt. Ltd. Vs. ACIT reported in 26 SOT 226 and the Delhi Bench of Tribunal in the case of Sony India Pvt. Ltd. reported in 114 ITD 448. The learned Authorized Representative for the assessee in this regard placed reliance on the ratio laid down by the Pune Bench of Tribunal in MSC Software Corporation India Pvt. Ltd. Vs. ACIT in ITA No.46/PUN/2013, relating to assessment year 2008-09, order dated 22.03.2017. 19. We find that the issue is squarely covered by earlier decisions of…

Msc Software Corporation India P.Ltd., Pune vs. Deputy Commissioner of Income-Tax

In the result, the appeal of assessee is partly allowed in the terms aforesaid

ITA 379/PUN/2014[2009-10]Status: DisposedITAT Pune31 May 2018AY 2009-10

Bench: Shri Anil Chaturvedi, Am & Shri Vikas Awasthy, Jm

For Appellant: Shri Rajendra AgiwalFor Respondent: Shri Sandeep Garg

Section 143(3)

…computed as difference between the PLR and the risk free rate of turn. The assessee prepared a summary computation considering the aforesaid rule, which reads as under:- 33. Further, the Delhi Bench of Tribunal in the case of Sony India Pv t. Ltd. reported in 114 ITD 448 has allowed 20% risk adjustment considering the fact that it may not be possible to quantify risk adjustments. The assessee applying the said ratio in the case of Sony India Pvt. Ltd. (supra) has worked out the risk adjustment on the operating margins of comparables to be allowed when computed @ 20%.” 34. Following the said ratio, we direct the A…

Global Logic Technologies Limited, Hyderabad vs. ACIT, Circle-2(2) Hyderabad, Hyderabad

In the result, assessee’s appeal is allowed

ITA 1672/HYD/2016[2012-13]Status: DisposedITAT Hyderabad23 May 2018AY 2012-13

Bench: Smt. P. Madhavi Devi & Shri S.Rifaur Rahmanm/S. Global Logic Vs Asstt. Commissioner Of Technologies Ltd Income Tax, Circle 2(2) Hyderabad Hyderabad Pan: Aadcr5222K (Appellant) (Respondent)

For Appellant: Shri K.C. DevdasFor Respondent: Shri K. Srinivas Reddy, DR

Section 143(3)

…will be allowed as a deduction even though the liability pertains to another year. He also placed Page 4 of 7 ITA No 1672 of 2016 Globallogic Technologies Ltd Hyderabad. reliance upon the decision of the Tribunal in the case of Sony India (P) Ltd vs. DCIT 114 ITD 448 to argue that where the expenditure pertaining to a particular A.Y is accounted in another A.Y, the same cannot be disallowed in both the A.Ys. Thus, he prayed that if the expenditure is not to be allowed in the A.Y 2012-13, the same should be directed to be allowed in the A.Y 2013-14. 6. The learned DR, on the other hand, supported the orders of…