https://www.taxtmi.com/caselaws?id=343629 The Tribunal set aside the adjustments made by the Transfer Pricing Officer (TPO) regarding Advertisement, Marketing, and Promotion (AMP) expenses for assessment years 2010-11 and 2011-12. It directed the Assessing Officer/TPO to reevaluate the arm's length price (ALP) of AMP expenses, considering the conflicting judgments on whether AMP expenses constitute an international transaction. The Tribunal emphasized the need for a fresh determination, allowing the assessee a reasonable opportunity of hearing. Additionally, the Tribunal instructed the use of Resale Price Method (RPM) as the most appropriate method for determining the ALP of the international transaction, with AMP intensity adjustment in the profit margins of comparables. en-us Fri, 26 May 2017 00:00:00 +0530 Tue, 30 May 2017 06:03:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=343629 The Tribunal set aside the adjustments made by the Transfer Pricing Officer (TPO) regarding Advertisement, Marketing, and Promotion (AMP) expenses for assessment years 2010-11 and 2011-12. It directed the Assessing Officer/TPO to reevaluate the arm's length price (ALP) of AMP expenses, considering the conflicting judgments on whether AMP expenses constitute an international transaction. The Tribunal emphasized the need for a fresh determination, allowing the assessee a reasonable opportunity of hearing. Additionally, the Tribunal instructed the use of Resale Price Method (RPM) as the most appropriate method for determining the ALP of the international transaction, with AMP intensity adjustment in the profit margins of comparables. Case-Laws Income Tax Fri, 26 May 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=343629