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Valvoline Cummins Pvt. Ltd., New Delhi vs Dcit, New Delhi on 26 November, 2018 cites

Maruti Suzuki India Ltd., New Delhi vs Addl. Cit, New Delhi on 17 October, 2018

12. It is the submission of Mr. Vohra that, as explained by this Court in Sony Ericsson India Pvt. Ltd.(supra) and later in Maruti Suzuki India Limited v. CIT(2016) 328 ITR 210 (Del), a basic requirement had to be fulfilled prior to commencing the exercise of determining the ALP of an international transaction. The Revenue had to discharge its onus of showing that there was an international transaction involving the Assessee and its AE with regard to the AMP expenses. If the Revenue failed to discharge this onus then the question of the further step of determining the ALP of such AMP expenses does not arise.
Income Tax Appellate Tribunal - Delhi Cites 243 - Cited by 39 - Full Document

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

15. The decision in Le Passage to India Tour & Travels (P) Ltd.(supra) turned on the fact that there was no determination by the TPO in the first place whether there was an international transaction. In the present case, however, the TPO did apply his mind to the existence of an international transaction involving AMP expense. The only ground on which the conclusion was reached by the TPO was that the AMP expenditure incurred by the Assessee was in excess of that incurred by the comparables. His 11 ITA No.527/Del/2016 conclusion was not based on any other factor. In other words, it was not as if the conclusion arrived by the TPO was based on two or three grounds, one of which was the BLT.
Supreme Court - Daily Orders Cites 0 - Cited by 193 - Full Document

Lg Electronics India (P) Ltd., New Delhi vs Acit, Noida on 18 July, 2018

7. It is the case of the taxpayer that AMP expenditure is a domestic transaction and not an international transaction. However, the TPO by relying upon the decision rendered by ITAT, Special Bench in LG Electronics India Pvt. Limited vs. ACIT - (2013) 22 ITR (Trib.) 1 observed that the taxpayer has incurred AMP expenditure much higher than the comparable and on brands not owned by it and preferred to benchmark on transaction by transaction basis.
Income Tax Appellate Tribunal - Delhi Cites 61 - Cited by 13 - Full Document
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