Tax deduction compliance and payee income recognition govern consultancy disallowance, while no exempt income prevents related expenditure disallowanc...
Derivative abetment liability fails when correctly declared imported components establish no underlying improper importation by the principal importer...
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.
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