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1. TPA - AMP expenses - Revenue has not been able to demonstrate that there exists an international transaction involving the Assessee and a foreign AE on the question of...

2. TP Adjustment - existence of international transaction of AMP Expenses - the revenue has also substantially proved the onus of existence of international transaction...

3. TP adjustment - AMP expenses - the existence of an international transaction will have to be established de hors the BLT, the burden is on the Revenue to first show the...

4. TP Adjustment - excessive AMP expenses - third party also benefits - Revenue also could not demonstrate the presence of any machinery provision to compute Arm’s Length...

5. TP Adjustment - international transaction - in the absence of no written agreement exists between the assessee and its AE requiring the assessee to incur AMP expenses,...

6. TP Adjustment - international transactions u/s. 92B or not - In absence on any such agreement, the first and primary condition of holding the transaction in question as...

7. TPA - computation of ALP of the international transactions by applying BLT - ALP of an international transaction involving AMP expenses, the adjustment made by the...

8. ALP - brand promotion expenses - TPO has not been able to prove that the AMP expenses incurred was not for the benefit of the assessee - The payment made by the assessee...

9. TP adjustments towards AMP expenditure pertaining to trading segment AND reimbursement of warranty expenses to AE - the AMP expenses and warranty expenses cannot be...

10. TPA - receivables forming a part of international transaction - TPO is not justified in concluding that the figure of receivables beyond 180 days constitutes an...

11. TP Adjustment - adjustment on account of AMP - we cannot infer the existence of international transactions qua AMP expenses between taxpayer and AE beyond the...

12. TP adjustment on account of AMP expenditure - International transaction u/s 93B - Unless it was shown that there was such an arrangement which resulted into any direct...

13. TP adjustment - fees for management services(FMS) - TNMM - it is quite possible that a probable addition on account of TP adjustment arising from one or more of the...

14. TP adjustment on account of reimbursement of seafarer expenses - Revenue has only doubted the genuineness of the alleged reimbursement of expenses made by the assessee...

15. TP Adjustment - adjustment made on account of advertisement, marketing and promotion (AMP) expenses - internatinal transaction - the AMP expenditure incurred by the...