Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Page of 4809
Press 'Enter' after typing page number.
1381 to 1400 of 96177 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
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.