Tag: Bright Line Test (BLT)

India vs Sony India Pvt. Ltd., August 2025, Income Tax Appellate Tribunal, Case ITA No.9080/Del/2019, ITA No.1688/Del/2022, and ITA No.2052/Del/2022

India vs Sony India Pvt. Ltd., August 2025, Income Tax Appellate Tribunal, Case ITA No.9080/Del/2019, ITA No.1688/Del/2022, and ITA No.2052/Del/2022

Sony India faced transfer pricing adjustments across multiple assessment years covering AMP expenses, royalty payments, and advisory services. India's Income Tax Appellate Tribunal held that neither the Bright Line Test nor intensity adjustments are permissible benchmarking methods under the Income Tax Act, deleting both AMP and royalty adjustments. The Tribunal also directed revisions to the comparables set for advisory services, deciding the case mostly in Sony's favour ... Read more