https://www.taxtmi.com/caselaws?id=325775 The Tribunal held that Transfer Pricing adjustments on Advertisement, Marketing, and Promotion (AMP) expenditure cannot be presumed as an international transaction without explicit agreements, directing the revenue to prove such transactions. Disallowance under Section 14A was remitted back for a de novo consideration to ensure proper examination. Additional disallowances like Bad Debts, Software Expenses, Warranty Expenses, and Product Launch Expenses were allowed based on specific directions. The appeal challenging the interest levy under Section 234C was partly allowed, with the Tribunal emphasizing adherence to legal standards and a balanced approach in its judgment. en-us Fri, 05 Feb 2016 00:00:00 +0530 Mon, 28 Mar 2016 13:21:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=325775 The Tribunal held that Transfer Pricing adjustments on Advertisement, Marketing, and Promotion (AMP) expenditure cannot be presumed as an international transaction without explicit agreements, directing the revenue to prove such transactions. Disallowance under Section 14A was remitted back for a de novo consideration to ensure proper examination. Additional disallowances like Bad Debts, Software Expenses, Warranty Expenses, and Product Launch Expenses were allowed based on specific directions. The appeal challenging the interest levy under Section 234C was partly allowed, with the Tribunal emphasizing adherence to legal standards and a balanced approach in its judgment. Case-Laws Income Tax Fri, 05 Feb 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=325775