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3. In ground nos. 8 to 8.14, the assessee has challenged the transfer pricing adjustment of Rs.28,81,09,571/- relating to determination on arm's length price of expenditure incurred by the assessee for advertisement, marketing and promotion (AMP) of the brand of Associated Enterprises (AEs) 3.1 Briefly the facts relating to this issue are, the assessee is a resident corporate entity and is a part of Xerox group of companies. As stated by the Assessing Officer, the assessee is engaged in the business of providing a range of office equipments, software solution and document management services. The assessee sells xerographic equipments, printers, scanners, multifunctional devices, high-end equipments etc. In course of proceeding under section 92CA of the Act, the Transfer Pricing Officer (TPO) noticed that the assessee had incurred expenditure on AMP. After calling for and examining the necessary details, he observed that by incurring such expenditure, the assessee is