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Maruti Suzuki India Ltd. (Earlier Known ... vs Commissioner Of Income Tax Delhi on 26 February, 2019

The problem does not stop here. Even if a transaction involving an AMP spend for a foreign AE is able to be located in some agreement, written (for e.g., the sample agreements produced before the Court by the Revenue) or otherwise, how should a TPO proceed to benchmark the portion of such AMP spend that the Indian entity should be compensated for? 63. Further, in Maruti Suzuki India Ltd. '(supra) the Court further explained the absence of a 'machinery provision qua AMP expenses by the following analogy: "75. As an analogy; and from other purpose; in the- context of a domestic transaction involving two or more related parties, reference may' be made to Section 40 A (2) (a) under which certain types of expenditure incurred by way of payment to related parties is not deductible where the AO is of the opinion that such expenditure is excessive or unreasonable having regard to the fair market value of the goods." In such event, so much of the expenditure as is so considered by him to be excessive or unreasonable shall not be allowed as a deduction." The AO in such an instance deploys the 'best judgment' assessment as a device to disallow what he considers to be an excessive expenditure. There is no corresponding 'machinery' provision in Chapter X which enables' an AO to determine what should be the fair 'compensation' an Indian entity would be entitled to if it is found' that there is an International transaction in that regard. In practical terms, absent a clear statutory guidance, this may encounter further difficulties. The strength of a brand, which could be product specific, may be "impacted by numerous other imponderables not limited to the nature of the industry, the geographical peculiarities, economic trends both international and domestic, the consumption patterns, market behaviour and so on.A simplistic approach using one of the modes similar to the ones contemplated by Section 92C may not only be legally impermissible but will lend itself to arbitrariness. What is then needed is a clear statutory scheme encapsulating the legislative policy and mandate which provides the necessary checks against arbitrariness while at the same time addressing the apprehension of tax avoidance." 64. In the absence of any machinery provision, bringing an imagined transaction to tax is not possible.
Supreme Court - Daily Orders Cites 0 - Cited by 13 - Full Document

Sony Ericsson Mobile Communication ... vs Commissioner Of Income Tax-Iii on 11 February, 2016

It was also observed by him that the issue of aggregation/segregation was also to be decided in light of the judgment of the Hon‟ble High Court of Delhi in the case of Sony Ericsson Mobile Communications India Pvt. Ltd. (supra). Further, it was noticed by the DRP that the TPO was also directed not to alter the comparables which were selected by him. The DRP after necessary deliberations observed, that in the case of Maruti Suzuki India Pvt. ltd. Vs. CIT (2016) 381 ITR 117 (Del) the Hon‟ble High Court of Delhi was dealing with a different category of assesse viz. a licensed manufacturer. In the backdrop of the aforesaid facts, it was observed by the DRP that as the case of the assessee before them was that of a pure distributor and not as that of a manufacturer, therefore, the various decisions relied upon by it could not be followed for arriving at a proper conclusion. It was further observed by the DRP that the claim of the assessee that the advertising activity carried out by it was an independent activity and was not done in close co-ordination with the actual brand owner, or that it was being done only with the view to ensure efficient distribution/routine marketing and had no Page |9 ITA Nos.1997/Mum/2018 &ITA No.2168/Mum/2014 & C.O. No.213/Mum/2014 (Arising out of ITA No. 2121/Mum/2014) ITA No. 2121/Mum/2014 & AY. 2009-10 relationship with the DEMPE functions, could not be accepted. Also, it was observed by the DRP that though the assessee had tried to follow the aggregated approach, however, it had not discussed the AMP expenditure in its TP study report and there was no evidence that its comparables had been selected with a view to ensure that they were performing similar marketing functions. On the contrary, it was observed by the DRP that in addition to the significantly high AMP expenses, the nature of the services which were necessary for selling the products which admittedly were not being rendered by the AEs in India clearly revealed that the assessee was performing the DEMPE functions on behalf of its AE. Also, it was observed by the DRP that though the assessee had claimed that as it had adopted an aggregate approach, therefore, the AMP transactions should be treated as having been aggregated with the other transactions while conducting the TNMM analysis did not merit acceptance in the absence of any supporting evidence. Further, it was observed by the DRP that just because the AMP expenses formed part of the expenditure incurred while conducting the TNMM, it could not be held that the TNMM included the AMP expenditure. Accordingly, it was observed by the DRP that the aggregation approach could not be taken as the correct approach in the case of the assessee. Infact, it was observed by the DRP that as the AMP expenses had not been benchmarked by the assessee at all, therefore, they were required to be identified as a separate transaction for the purpose of their benchmarking. The DRP also declined to accept the claim of the assessee that the AMP expenses incurred were in context of its own sales efforts and any benefit to the AE was incidental. On the basis of the aforesaid observations, it was concluded by the DRP that the assessee had rendered significant DEMPE services to its AE which constituted an P a g e | 10 ITA Nos.1997/Mum/2018 &ITA No.2168/Mum/2014 & C.O. No.213/Mum/2014 (Arising out of ITA No. 2121/Mum/2014) ITA No. 2121/Mum/2014 & AY. 2009-10 independent international transaction and was required to be benchmarked separately. Further, the claim of the assessee that the TPO had wrongly rejected the „bundled approach‟ that was adopted by the assesse for benchmarking the transactions of purchase of finished goods and other associated transactions, and was thus in error in separately benchmarking the AMP expenses also did not find favour with the DRP. On the basis of its aforesaid observations the DRP directed the TPO to recompute the adjustments as per the directions contained in its order.
Supreme Court - Daily Orders Cites 0 - Cited by 193 - Full Document

India Medtronic Private Limited vs Deputy Commissioner Of Income Tax on 6 February, 2019

In Whirlpool of India Ltd. (supra), the Court interpreted the expression "acted in concert" and in that context referred to the decision of the Supreme Court in Daiichi Sankyo Company Ltd. v. Jayaram Chigurupati 2010(6)MANU/SC/0454/2010, which arose in the context of acquisition of shares of Zenotech Laboratory Ltd. by the Ranbaxy Group. The question that was examined was whether at the relevant time the Appellant, i.e., 'Daiichi Sankyo Company and Ranbaxy were "acting in concert" within the meaning of Regulation 20(4) (b) of the Securities and Exchange Board of India (Substantial Acquisition of Shares and Takeovers) Regulations, 1997. In. para 44, it was observed as under:"
Bombay High Court Cites 2 - Cited by 3 - Full Document

Commissioner Of Income Tax, Bangalore ... vs B. C. Srinivasa Setty, Etc. Etc on 19 February, 1981

The decisions in CIT v. B.C. Srinivasa Setty (1981) 128 ITR 294 (SC) and PNB Finance Ltd. v, CIT (2008) 307 ITR 75 (SC) make this position explicit. Therefore, where the existence of an international transaction involving AMP expense with an ascertainable price is- unable to be shown to exist, even if such price is nil, Chapter X provisions cannot be invoked to undertake a TP adjustment exercise. 1261 & 1238/M/15 Thomas Cook 33 65.
Supreme Court of India Cites 18 - Cited by 859 - R S Pathak - Full Document

Pnb Finance Ltd vs Commissioner Of Income Tax-I, New Delhi on 6 November, 2008

The decisions in CIT v. B.C. Srinivasa Setty (1981) 128 ITR 294 (SC) and PNB Finance Ltd. v, CIT (2008) 307 ITR 75 (SC) make this position explicit. Therefore, where the existence of an international transaction involving AMP expense with an ascertainable price is- unable to be shown to exist, even if such price is nil, Chapter X provisions cannot be invoked to undertake a TP adjustment exercise. 1261 & 1238/M/15 Thomas Cook 33 65.
Supreme Court of India Cites 15 - Cited by 104 - S H Kapadia - Full Document
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