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    <title>2014 (1) TMI 1529 - ITAT DELHI</title>
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    <description>The AMP transfer pricing framework was applied to hold that the Transfer Pricing Officer could examine advertisement, marketing and promotion expenses, but amounts shown as pricing adjustment or extra trade discount, being dealer incentives and not true AMP spend, had to be excluded from the AMP base. The component said to represent salaries to demonstrators required fresh verification, along with comparable selection, and was remitted for reconsideration. The alternative disallowance under section 37(1) was deleted because the same AMP expenditure could not be again disallowed as not wholly and exclusively for business once it had been examined under transfer pricing rules. The appeal was thus partly allowed.</description>
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      <title>2014 (1) TMI 1529 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=243314</link>
      <description>The AMP transfer pricing framework was applied to hold that the Transfer Pricing Officer could examine advertisement, marketing and promotion expenses, but amounts shown as pricing adjustment or extra trade discount, being dealer incentives and not true AMP spend, had to be excluded from the AMP base. The component said to represent salaries to demonstrators required fresh verification, along with comparable selection, and was remitted for reconsideration. The alternative disallowance under section 37(1) was deleted because the same AMP expenditure could not be again disallowed as not wholly and exclusively for business once it had been examined under transfer pricing rules. The appeal was thus partly allowed.</description>
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      <pubDate>Mon, 13 Jan 2014 00:00:00 +0530</pubDate>
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