under Section 92CA(1) to the Transfer Pricing Officer
(TPO) for the determination of Arm's Length Price (ALP) of the
international transactions ... Section 92CA(3) of the Act proposed,
inter alia, the following transfer pricing adjustments:
SNo. Additions/Disallowances Amount (INR)
1 Payment of Royalty for brand
under Section 92CA(1) to the Transfer Pricing Officer
(TPO) for the determination of Arm's Length Price (ALP) of the
international transactions ... Section 92CA(3) of the Act proposed,
inter alia, the following transfer pricing adjustments:
SNo. Additions/Disallowances Amount (INR)
1 Payment of Royalty for brand
under Section 92CA(1) to the Transfer Pricing Officer
(TPO) for the determination of Arm's Length Price (ALP) of the
international transactions ... Section 92CA(3) of the Act proposed,
inter alia, the following transfer pricing adjustments:
SNo. Additions/Disallowances Amount (INR)
1 Payment of Royalty for brand
being quashed.
TRANSFRR PRICING GROUNDS
Re: Transfer Pricing Adjustment in respect of Advertisement,
Marketing and Promotion Expenses("AMP Expenses")
3. That ... Proceedings before Transfer pricing Officer resulting in TP order
dated 27th January 2014 (refer pages 1 to 103 of Appeal set)
Transfer pricing officer issued
being quashed.
TRANSFRR PRICING GROUNDS
Re: Transfer Pricing Adjustment in respect of Advertisement,
Marketing and Promotion Expenses("AMP Expenses")
3. That ... Proceedings before Transfer pricing Officer resulting in TP order
dated 27th January 2014 (refer pages 1 to 103 of Appeal set)
Transfer pricing officer issued
Transfer Pricing Study
('TP Study') Transfer Pricing grounds
Grounds pertaining to the alleged Advertisement, Marketing and Promotion ('AMP')
expenses
3. AMP ... disclosed
price. The transfer pricing adjustment envisages the substitution of the
price of such international transaction with the ALP.
64. The transfer pricing adjustment
Resolution Panel ("DRP")/AO/Transfer Pricing Officer ("TPO") erred in making a
transfer pricing adjustment ... hold that the transfer
pricing adjustments to the arm's length price of the alleged international
transaction of AMP expenditure of the appellant
determination by the ITAT in respect of validity of Transfer
Pricing adjustment towards AMP expenditure?
(b) Whether in facts and circumstances of present case,
impugned ... does not
finally and conclusively delete Transfer Pricing adjustment
made towards AMP expenditure?
4. Let these appeals be called again on 29.08.2024.
YASHWANT VARMA
simultaneously,
transfer pricing proceedings were initiated by the learned
Transfer Pricing Officer (learned TPO) under Section 92CA(2) of
the Act. The learned TPO proposed ... against the
said draft order which consists of transfer pricing and non-
transfer pricing adjustment / additions/disallowances. The ld.
DRP has disposed off the objections
Appellant, towards value added function under Advertising, Marketing and
Promotion ("AMP") activity and not excluding the corresponding expense ... Appellant.
15. without prejudice to above, erred in not restricting the transfer pricing
adjustment to the value of international transaction;
16. without prejudice to above
