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        Case ID :
        Income Tax

        ITAT adjudicated multiple transfer pricing disputes, rendering...

        Transfer Pricing Disputes Resolved: AMP Expenses Invalidated, Debt Instruments Affirmed, Methodology Challenged

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                          Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
                            Provisions expressly mentioned in the judgment/order text.
                                ITAT adjudicated multiple transfer pricing disputes, rendering key holdings: The tribunal invalidated adjustments related to advertising and marketing (AMP) expenses, following precedential high court rulings that such expenditures do not constitute international transactions. Protective adjustments under Bright Line Test (BLT) and Transactional Net Margin Method (TNMM) were deleted. Compulsorily Convertible Debentures (CCDs) were affirmed as debt instruments, rejecting tax authority's recharacterization as equity. The tribunal also found improper transfer pricing methodology in interest receivables calculation, deleting upward adjustments. Regarding resale of designated services, the tribunal set aside Dispute Resolution Panel's (DRP) findings and directed reconsideration of comparable selection in accordance with legal principles.
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