Head Office cost allocation requires prescribed transfer-pricing methods; treaty ceilings bar surcharge and cess, while duplicate taxation is excluded...
Cost-to-cost reimbursement of seconded employees is not service consideration; transfer-pricing markup was deleted and amalgamation amortisation allow...
Crystallisation of liability supports prior-period expense deduction, while functionally distinct divisions require separate transfer-pricing benchmar...
Functional comparability under TNMM requires transaction-specific FAR analysis before benchmarking business-support services provided to associated en...
Advance pricing agreement methodology can guide benchmarking for non-covered years when functions, assets, risks and activities remain materially unch...
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Advertisement, marketing and promotion (AMP) expenditure did not constitute an international transaction for transfer-pricing purposes, consistent with earlier orders concerning the assessee. Because an arm's length price adjustment presupposes an international transaction, no adjustment could be made for that expenditure. The deletion of the AMP adjustment was sustained, the Revenue's appeals were dismissed, and the assessee's cross-objections became infructuous.
Advertisement, marketing and promotion (AMP) expenditure did not constitute an international transaction for transfer-pricing purposes, consistent with earlier orders concerning the assessee. Because an arm's length price adjustment presupposes an international transaction, no adjustment could be made for that expenditure. The deletion of the AMP adjustment was sustained, the Revenue's appeals were dismissed, and the assessee's cross-objections became infructuous.
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