Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding
  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights April 2025 Year 2025 This

HC determined that AMP expenditure does not constitute a ...


Advertising and Marketing Promotion Costs Not Considered Separate Transaction Under Transfer Pricing Rules

April 9, 2025

Case Laws     Income Tax     HC

HC determined that AMP expenditure does not constitute a separate international transaction requiring transfer pricing adjustment. The Tribunal consistently applied precedential principles from prior cases, concluding that AMP expenditure cannot be benchmarked as an independent transaction. Consequently, the Transfer Pricing Officer's adjustment was deleted across multiple assessment years. The court affirmed the Tribunal's reasoning, finding no merit in remanding the matter for further investigation. The assessee's appeal was allowed, effectively eliminating the proposed transfer pricing adjustment related to AMP expenditure.

View Source

 


 

You may also like:

  1. Transfer pricing adjustment - arm‘s length pricing of international transactions - Advertising / Marketing and Promotion Expenses - international transaction - Domestic...

  2. Transfer pricing officer (TPO) erred by considering non-associated enterprise (non-AE) revenue and costs while computing transfer pricing (TP) adjustment, contrary to...

  3. Valuation - Inclusion of expenditure incurred towards advertising, marketing and promotion of the goods - The Tribunal emphasized that for costs to be added to the...

  4. Transfer pricing adjustment - arm's length price of broking commission - selection of most appropriate method - considering brokerage rate of all non-associates for...

  5. 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...

  6. Transfer pricing adjustment on equity broking services (non-DVP segment/CH settlement) rejected due to negligible difference of 0.01% after considering cost adjustment...

  7. Determining the ALP under transfer pricing provisions - Determination of market value of of electricity - When a captive power plant in an industry supplies electricity...

  8. Addition made towards profit in money market operations - in this case the physical delivery has not taken place and therefore the transactions of sale and purchase of...

  9. Transfer pricing adjustment made to alleged international transaction of AMP expenditure incurred by assessee disallowed due to lack of evidence that assessee agreed to...

  10. The proposed amendment seeks to address a lacuna in the computation of cost of acquisition under clause (ac) of sub-section (2) of section 55 of the Income Tax Act, 1961...

  11. Addition on account of diamond set received as gift by the appellant - The CIT(A) accepted the appellant's submission that the diamond set was indeed gifted by his late...

  12. Levy of GST - distinct persons - supply of goods or supply of services - The transfer of right to do integration testing, installation and marketing software from the...

  13. This circular modifies the valuation methodology for repurchase (repo) transactions, including tri-party repo (TREPS), by mutual funds. Previously, repo transactions up...

  14. Transfer pricing adjustment - Correspondent Banking Activities - The main business transactions have been accepted to be at arm’s length and hence, the ld. TPO cannot...

  15. TP adjustment on account of back-to-back counter bank guarantee - TPO, by considering the rate charged by Bank of Baroda for issuance of guarantee against 100% counter...

 

Quick Updates:Latest Updates