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2016 (11) TMI 1648 - SCH - Income TaxTPA - AMP expenses - existence of an international transaction - whether advertising marketing and promotion expenses ( AMP ) incurred by the Assessee can be said to be incurred not only for the benefit of the Assessee but also by way of rendering the services of promoting the brand of the foreign associated enterprise ( AE ) namely B L USA? - Existence of an international transaction - re-characterization of its transaction involving its AE for the two years - HELD THAT - Delay condoned. Leave granted.
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