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    <title>2017 (4) TMI 716 - ITAT DELHI</title>
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    <description>The case involved the addition of significant amounts due to transfer pricing adjustment of advertisement, marketing, and promotion (AMP) expenses for two assessment years. The High Court directed a fresh determination of the arm&#039;s length price (ALP) of AMP expenses, emphasizing the need to consider AMP expenses as international transactions and determine the ALP based on comparability with functions performed by the assessee and comparables. The Tribunal was instructed to assess the nature of expenses, excluding selling expenses directly related to sales when computing the ALP. The appeal was partly allowed for statistical purposes, stressing the importance of a detailed examination of AMP functions and expenses for transfer pricing adjustments.</description>
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      <title>2017 (4) TMI 716 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=341746</link>
      <description>The case involved the addition of significant amounts due to transfer pricing adjustment of advertisement, marketing, and promotion (AMP) expenses for two assessment years. The High Court directed a fresh determination of the arm&#039;s length price (ALP) of AMP expenses, emphasizing the need to consider AMP expenses as international transactions and determine the ALP based on comparability with functions performed by the assessee and comparables. The Tribunal was instructed to assess the nature of expenses, excluding selling expenses directly related to sales when computing the ALP. The appeal was partly allowed for statistical purposes, stressing the importance of a detailed examination of AMP functions and expenses for transfer pricing adjustments.</description>
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