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| The Tax Publishers2020 TaxPub(DT) 0922 (Kol-Trib) INCOME TAX ACT, 1961
Section 92B
AMP expenses could not be regarded as an international transaction between AEs so as to invoke provisions of section 92, therefore, no TP adjustment was called for.
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Transfer pricing - International transaction - AMP expenses -
Assessee incurred advertisement, marketing and promotion (AMP) expenses. TPO treated this as international transaction for benefit of its AE abroad and, therefore, calling for ALP adjustment.Held: AMP expenses could not be regarded as an international transaction between AEs so as to invoke provisions of section 92, therefore, no TP adjustment was called for.
Supported:Maruti Suzuki India Ltd. v. CIT (2015) 381 ITR 117 (Del) : 2015 TaxPub(DT) 5219 (Del-HC).
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2013-14
INCOME TAX ACT, 1961
Section 14A Section 115JB
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