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| The Tax Publishers2020 TaxPub(DT) 3525 (Kol-Trib) INCOME TAX ACT, 1961
Section 92B
AMP expenses were not excessive and were found to be at arm's length and, therefore, same could not be treated as brand promotion for AE and, therefore, incurrence of AMP expenses did not constitute international transaction.
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Transfer pricing - International transaction - AMP expenses -
Assessee claimed deduction of AMP expenses incurred by it. TPO treated the same as international transaction in the nature of promotion of brand owned by overseas AE and thus calling for TP adjustment. Held: AMP expenses were not excessive and were found to be at arm's length and, therefore, same could not be treated as brand promotion for AE and, therefore, incurrence of AMP expenses did not constitute international transaction.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. :
IN THE ITAT, KOLKATA BENCH
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