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of <h1>Corporate Marketing Expenses Not Deemed Separate International Transaction Under Transfer Pricing Regulations</h1> <h3>Pr. Commissioner Of Income Tax-7, Delhi Versus M/s Wrigley India Pvt. Ltd.</h3> Pr. Commissioner Of Income Tax-7, Delhi Versus M/s Wrigley India Pvt. Ltd. - 2025:DHC:2881 - DB The Delhi High Court, through Justice Vibhu Bakhrru (oral judgment), dismissed the Revenue's appeal (ITA 112/2025) challenging the Income Tax Appellate Tribunal's (ITAT) order dated 24.07.2024 for AY 2012-13. The impugned order upheld the CIT (A)'s finding that Advertising, Marketing and Promotional (AMP) expenses do not constitute a separate international transaction and thus cannot be benchmarked using the Bright Line Test (BLT). The Transfer Pricing Officer's reliance on external materials to treat AMP expenses as international transactions was rejected. The Court emphasized that AMP expenses incurred in the normal course of business, without material establishing a transaction between the Assessee and its associate enterprises, do not qualify as international transactions. This position aligns with precedents including Sony Ericsson Mobile Communication India Pvt. Ltd. v. CIT-3, Maruti Suzuki India Ltd. v. CIT, and the Court's own earlier decision in Principal Commissioner of Income Tax-9 v. Wrigley India Pvt. Ltd. The Court found 'no substantial questions of law arise' and accordingly dismissed the appeal.
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