made a reference to the
Transfer Pricing Officer ('TPO'). During the transfer pricing, the TPO
observed that the Assessee has incurred more than ... party. Transfer Pricing valuation,
therefore, would be mandated at that time. The international
transaction could then be made a subject matter of transfer
pricing
transfer pricing adjustment is not expected to be made by
deducing from the difference between the 'excessive' AMP
expenditure incurred by the Assessee ... seller.
14. The issue with respect to deletion of transfer pricing adjustment on
account of AMP expenses, determined on BLT method, by the ITAT
case for AY 2011-12, deleting the transfer pricing adjustment made
on account of AMP expenditure has been upheld by the predecessor bench
of this ... questions of law.
13. Consequently, on the issue of transfer pricing adjustment on
account of AMP expenditure, the present appeals are disposed of in terms
made a reference to the
Transfer Pricing Officer ('TPO') for determining the Arms's Length Price
('ALP') of the international ... contention of the Revenue. The deletion
of the transfer pricing adjustment on account of the AMP expenditure
proposed by applying BLT method is impermissible
regard to advertising, marketing and publicity (AMP)
expenses and in remanding the matter to the Assessing
Officer/Transfer Pricing Officer for determining the arms
length
directed to delete the
addition made on account of transfer pricing adjustment for transaction
related to royalty.
4. Aggrieved by the order ... length on consideration of Advertisement, Marketing and Promotion
('AMP') expenses incurred by the assessee for the benefit of the AE's
trademark
impugned
order, the ITAT has remanded the matter back to the Transfer Pricing
Officer ('TPO') and directed it to consider the combined effect ... determining the existence of an
international transaction involving AMP is expenses no longer
legally permissible. In that scenario, there would be a need
