https://www.taxtmi.com/caselaws?id=169845 Advertisement, marketing and sales promotion (AMP) spend was held, applying the Special Bench majority in LG Electronics, to constitute an international transaction under s.92B where it created/improved marketing intangibles for the foreign AE; the AMP adjustment was therefore permissible, but the ALP determination was remitted to the TPO for applying a prescribed method and reconsidering comparables, and no adjustment was directed for AMP attributable to the domestic brand. Expenses connected with sales were held not to promote the foreign brand and thus fell outside AMP; the AO was directed to exclude such sales-related costs from the AMP base. Excess excise duty payment credited in PLA was treated as duty "paid" for s.43B; deduction was directed. Actuarially valued provision for post-retirement medical benefits was held accrued and ascertained under mercantile accounting; deduction was allowed. en-us Tue, 02 Apr 2013 00:00:00 +0530 Mon, 29 Dec 2025 16:08:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=169845 Advertisement, marketing and sales promotion (AMP) spend was held, applying the Special Bench majority in LG Electronics, to constitute an international transaction under s.92B where it created/improved marketing intangibles for the foreign AE; the AMP adjustment was therefore permissible, but the ALP determination was remitted to the TPO for applying a prescribed method and reconsidering comparables, and no adjustment was directed for AMP attributable to the domestic brand. Expenses connected with sales were held not to promote the foreign brand and thus fell outside AMP; the AO was directed to exclude such sales-related costs from the AMP base. Excess excise duty payment credited in PLA was treated as duty "paid" for s.43B; deduction was directed. Actuarially valued provision for post-retirement medical benefits was held accrued and ascertained under mercantile accounting; deduction was allowed. Case-Laws Income Tax Tue, 02 Apr 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=169845