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| The Tax Publishers2020 TaxPub(DT) 0533 (Del-Trib) INCOME TAX ACT, 1961
Section 92B
There did not exist any arrangement or undertaking between assessee and AE in connection with incurring of AMP expenses accordingly, same could not be treated as international transaction and therefore, no ALP adjustment was called for.
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Transfer pricing - International transaction - AMP expenses alleged as brand building excersice for benefit of AE abroad -
Assessee, a subsidiary of Whirlpool Corporation (WC), USA and engaged in production, sales and distribution of home appliances incurred advertisement, marketing and sales promotion (AMP) expenses for the products having brand name 'Whirlpool'. TPO treated this as international transaction for benefit of brand owned by AE abroad and thereby calling for ALP adjustment. Held: There did not exist any arrangement or undertaking between assessee and AE in connection with incurring of AMP expenses accordingly, same could not be treated as international transaction and therefore, no ALP adjustment was called for.
REFERRED :
FAVOUR : In assessee's favour
A.Y. :
INCOME TAX ACT, 1961
Section 37(1)
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