Pr. Commissioner of Income Tax-1 v. Casio India Company Pvt. Ltd.

1. FACTS OF THE CASE

Revenue challenged the ITAT order dated 19 July 2022 for AY 2017-18. The Tribunal had allowed Casio’s appeal by following a coordinate-bench decision. The High Court condoned 980 days’ delay in re-filing before considering the appeal.

Source: PDF pp.1–2, paras 1–3

2. DISCUSSION BY THE COURT

The Court followed its earlier Casio decisions in ITA 211/2022 and 67/2022 and noted the further decision in ITAs 415 and 416/2025. The reproduced reasoning concerns AMP adjustments and rejection of the bright-line test following Sony Ericsson. The figures and earlier assessment years in that quotation belong to those earlier cases.

Source: PDF pp.2–4, paras 4–5

3. JUDICIAL DECISION

For the same reasons as ITA 211/2022, ITA 505/2025 was dismissed because no substantial question of law arose.

Source: PDF p.4, para 6

4. OUTCOME

Assessee successful for AY 2017-18; the ITAT relief remains undisturbed.

Source: PDF p.4, para 6

5. Expert Comments

AKHB editorial analysis, distinct from the Court’s findings.

Identify the benchmark actually rejected

The adopted reasoning rejects the bright-line method used for AMP adjustments in the earlier Casio litigation. It supports comparison with the same issue and methodology, rather than a statement that every marketing expense is incapable of being an international transaction. The short present order does not independently examine every possible AMP arrangement.

Source: PDF pp.3–4

Separate present facts from quoted history

AY 2017-18 is the year before this Court. The Rs.5,92,56,798 proposed adjustment and Rs.7,65,16,936 upward adjustment appear in the quotation about AY 2011-12; they are not quantified relief for this appeal. Similarly, the quoted AY 2014-15 decision should not be relabelled as the current case.

Source: PDF pp.2–3

Read the outcome against the complete order

Page 2 refers to earlier decisions favouring the respondent/revenue, although Revenue is the appellant. The reproduced decisions and operative paragraph consistently dismiss Revenue’s appeals. The isolated party-label error does not reverse the result. Also, condonation of re-filing delay is separate from the substantive dismissal.

Source: PDF pp.1–4