disallowed in the earlier
years as part of the Transfer Pricing Adjustment on
account of AMP expenses.
(ii) Assessee has been bearing substantial portion ... disallowed
in the earlier years as part of Transfer Pricing
Adjustment on account of AMP expenses; and secondly,
assessee has been bearing substantial portion
disallowed in the earlier
years as part of the Transfer Pricing Adjustment on
account of AMP expenses.
(ii) Assessee has been bearing substantial portion ... disallowed
in the earlier years as part of Transfer Pricing
Adjustment on account of AMP expenses; and secondly,
assessee has been bearing substantial portion
Therefore, matter was referred to Transfer
Pricing Officer (for short, "TPO") for determination of
Arms' Length Price (for short ... after
analyzing the AMP expenditure incurred by the
comparables, suggested transfer pricing adjustment
crores arising from Transfer
Pricing Adjustment made on account of the expenditure
towards Advertisement, Marketing and Promotion (AMP).
The Tribunal observed that ... issue raised in the assessee's
appeal regarding Transfer Pricing Adjustment in respect of
AMP expenditure was a debatable one; and hence, after
finding
held that no independent entity would incur
such an elevated level of AMP expenses on
account of a brand held by some other entity ... DCIT V/s. Nike India Pvt. Ltd. To delete the
transfer pricing adjustment
held that no independent entity would incur
such an elevated level of AMP expenses on
account of a brand held by some other entity ... DCIT V/s. Nike India Pvt. Ltd. To delete the
transfer pricing adjustment
M/S Indus Towers Ltd vs The Deputy Commissioner Of Commercial ... on 7 September, 2011
Banhatti Co-Operative Spinning Mill ... vs Karnataka Electricity Board on 30 November, 1989
Equivalent citations
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Sri K Dinesh vs Sri Kumaraswany And Others on 30 August, 2010
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