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| The Tax Publishers2019 TaxPub(DT) 1060 (Del-Trib) INCOME TAX ACT, 1961
Section 92B
Where TPO treated incurrence of AMP expenses as an international transaction for benefit of 'Cannon' brand owned by AE abroad, matter was remanded for fresh determination in the light of agreements entered into by assessee with AE for purchase and resale of Cannon products in India.
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Transfer pricing - International transaction - Advertisement, marketing and promotional (AMP) expenses -
Assessee incurred advertisement, marketing and promotional (AMP) expenses. TPO treated this as an international transaction for benefit of 'cannon' brand owned by AE abroad.Held: Matter was remanded back to TPO for fresh determination in the light of agreements entered into by assessee with AE for purchase and resale of Cannon poducts in India.
REFERRED :
FAVOUR : Matter remanded.
A.Y. : 2010-13 & 2013-14
INCOME TAX ACT, 1961
Section 195 Section 9(1)(vii)
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