https://www.taxtmi.com/caselaws?id=358143 AMP expenditure should not be mechanically treated as brand-building for an associated enterprise where the comparables do not support that inference and the taxpayer's AMP-to-sales ratio is lower on recomputation; only selling expenses were required to be excluded for reworking the arm's length price. The same expenditure, once examined under Chapter X transfer pricing provisions, could not also be disallowed alternatively under section 37(1) on the same basis. The effect was that the transfer pricing adjustment survived only to the limited extent of recomputation after excluding selling expenses, while the separate section 37(1) disallowance was rejected. en-us Wed, 28 Mar 2018 00:00:00 +0530 Fri, 06 Apr 2018 07:46:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=358143 AMP expenditure should not be mechanically treated as brand-building for an associated enterprise where the comparables do not support that inference and the taxpayer's AMP-to-sales ratio is lower on recomputation; only selling expenses were required to be excluded for reworking the arm's length price. The same expenditure, once examined under Chapter X transfer pricing provisions, could not also be disallowed alternatively under section 37(1) on the same basis. The effect was that the transfer pricing adjustment survived only to the limited extent of recomputation after excluding selling expenses, while the separate section 37(1) disallowance was rejected. Case-Laws Income Tax Wed, 28 Mar 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=358143