marketing 5,044,649
expenses
Reimbursement of share of 72,435,827
advertisement expenses received from
Intel and Microsoft
Expenses i.r.o Receipt ... length level of AMP exp (% of 3.58%
sale)
Arm's length AMP 1,326,421,793
Amount actually spent on AMP
marketing 5,044,649
expenses
Reimbursement of share of 72,435,827
advertisement expenses received from
Intel and Microsoft
Expenses i.r.o Receipt ... length level of AMP exp (% of 3.58%
sale)
Arm's length AMP 1,326,421,793
Amount actually spent on AMP
Associated Enterprises (AEs) w.r.t. the
AMP spend; and
b. not appreciating that the AMP expenses incurred by the Appellant are wholly and
exclusively ... making duplicative adjustments on account of
AMP is perverse and contrary to law as the alleged AMP expenses and AMP
activities for the trading segment
Appellant, the
question of any adjustment on account of AMP expenses does not
arise;
4.3 not appreciating that the Appellant is the economic owner ... AMP or brand building exercise
by applying bright line test' of non-comparables and in all case,
costs or compensation paid for AMP expenses
have machinery provision to benchmark
the international transaction arising from AMP expenses.
4. Whether on the facts and circumstances of the case ... after discussing issue in detail has come to the
conclusion that AMP expenses incurred by the appellant
therein, cannot be treated and categorized
2013, has upheld that
Advertisement, Marketing and Promotion (AMP) expenses as
international transaction and has held that Arms Length Price (ALP)
of AMP expenses should ... been unable to demonstrate that there is
an international transaction involving AMP expenses between the
assessee and its foreign AE and that since BLT (Bright
relief and the adjustment made by
the TPO on account of AMP expenses has been reduced to NIL,
therefore, the Tribunal has rightly dismissed ... relief and the adjustment made by the TPO on
account of AMP expenses has been reduced to NIL, thus, the Appeal
itself has become
considered the
commission paid to ABOs as part of AMP expenses while the issue stands
covered in favour of the assessee ... treat the disputed commission as AMP expenditure and the remaining
adjustments made in regard to AMP expenses of non-routine nature the assessee
had succeeded
Uncontrolled Price (CUP). The TPO
also included amount of third party AMP Expenses while computing the
amount of adjustment for royalty, applied the TNMM Method
Uncontrolled Price (CUP). The TPO
also included amount of third party AMP Expenses while computing the
amount of adjustment for royalty, applied the TNMM Method
