Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
Objective characteristics govern magnesium bis-glycinate chelate classification as an amino-acid coordination compound, not a food preparation or anti...
Independent professional certification requires pleaded knowledge or complicity for criminal liability; untimely complaints remain barred by limitatio...
AMP expenditure incurred in India for the assessee's own sales and promotion could not be treated as an international transaction merely because it may incidentally benefit the foreign associated enterprise's brand. An agreement, arrangement or understanding between the parties is a condition precedent for transfer pricing adjustment, and higher expenditure or presumed brand-building benefit is insufficient. On that basis, the AMP adjustment was deleted. Consequentially, the AO was directed to allow set off of brought forward business loss and unabsorbed depreciation in accordance with law after giving a reasonable opportunity of being heard.
AMP expenditure incurred in India for the assessee's own sales and promotion could not be treated as an international transaction merely because it may incidentally benefit the foreign associated enterprise's brand. An agreement, arrangement or understanding between the parties is a condition precedent for transfer pricing adjustment, and higher expenditure or presumed brand-building benefit is insufficient. On that basis, the AMP adjustment was deleted. Consequentially, the AO was directed to allow set off of brought forward business loss and unabsorbed depreciation in accordance with law after giving a reasonable opportunity of being heard.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4798
Join Channel
TaxTMI 
