https://www.taxtmi.com/caselaws?id=193637 The High Court condoned the delay in refiling the appeals and allowed exemptions subject to exceptions. The court addressed the grievance regarding ITAT's observations on ALP determination, emphasizing that AMP expenses are to be included in ALP determination as part of international transactions. The appropriate method (RP or CUP method) depends on the business model. The court reiterated that there is no fixed rule for choosing the method. The ITAT's observation on the resale price method was to be interpreted in line with the criteria set in a previous judgment. The appeals were disposed of accordingly. en-us Tue, 25 Oct 2016 00:00:00 +0530 Thu, 10 Aug 2017 06:37:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=193637 The High Court condoned the delay in refiling the appeals and allowed exemptions subject to exceptions. The court addressed the grievance regarding ITAT's observations on ALP determination, emphasizing that AMP expenses are to be included in ALP determination as part of international transactions. The appropriate method (RP or CUP method) depends on the business model. The court reiterated that there is no fixed rule for choosing the method. The ITAT's observation on the resale price method was to be interpreted in line with the criteria set in a previous judgment. The appeals were disposed of accordingly. Case-Laws Income Tax Tue, 25 Oct 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=193637