The ITAT Delhi Bench, vide order dated 12.08.2026, allowed both appeals of Samsung India Electronics Pvt. Ltd. for AYs 2016-17 and 2017-18 against additions of Rs. 46.65 crore (AY 2016-17) and similar amounts for AY 2017-18 on AMP expenditure (including the Bright Line Test), royalty, expatriate salary disallowance and networking segment adjustments, directing deletion in view of the assessee’s own-case orders for AY 2005-06 to 2015-16, binding DRP directions under Section 144C(10) and the impermissibility of duplicative CUP/TNMM adjustments; both Stay Applications stand dismissed as infructuous, with liberty for re-computation of ALP as directed.
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