Risk-based postal import clearance standardises electronic assessment, document requests, duty realisation and delivery controls at Foreign Post Offic...
Customs Cargo Service Provider appointment extends custodianship to additional terminal land, subject to cargo-control, security and licence condition...
Post-search scrutiny assessment remains available where original assessment limitation is unexpired, permitting timely completion under regular assess...
Advertisement, marketing and promotion expenditure incurred for...
AMP expenditure for own business is not an international transaction without an associated-enterprise arrangement, eliminating transfer pricing adjustment.
Contents
Summary
Note
Bookmark
Share
✓ Copied successfully !
Print
Print Options
For full text, please login
Login to TaxTMI
Verification Pending
The Email Id has not been verified. Click on the link we have sent on
Advertisement, marketing and promotion expenditure incurred for an assessee's own business and market penetration does not constitute an international transaction merely because an associated enterprise receives an incidental benefit. An agreement or arrangement with the associated enterprise is required to establish such a transaction. The bright line test is not a recognised method for inferring an international transaction or making a transfer pricing adjustment. Applying earlier coordinate-bench decisions on materially identical facts, the AMP transfer pricing adjustment was deleted and the assessee's appeal was allowed.
Advertisement, marketing and promotion expenditure incurred for an assessee's own business and market penetration does not constitute an international transaction merely because an associated enterprise receives an incidental benefit. An agreement or arrangement with the associated enterprise is required to establish such a transaction. The bright line test is not a recognised method for inferring an international transaction or making a transfer pricing adjustment. Applying earlier coordinate-bench decisions on materially identical facts, the AMP transfer pricing adjustment was deleted and the assessee's appeal was allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
