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1. 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...

2. TPA - AMP expenses - Revenue has not been able to show the existence of an international transaction involving AMP expenses between the Assessee and its AE, B&L, USA. - HC

3. 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,...

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

5. 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...

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

12. TP Adjustment - adjustment on account of AMP expenditure - We are unable to accept the said contention of the learned counsel for the Revenue that since the Assessee...

13. The assessee had demonstrated the genuineness of the share transaction resulting in long-term capital gains, which were claimed as exempt u/s 10(38). The Revenue...

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

15. TPA - where the variation between the arm’s length price determined u/s 92C and the price at which the international transaction or specified domestic transaction has...