https://www.taxtmi.com/caselaws?id=366404 Transfer pricing treatment of AMP spend required verification of the contractual framework before it could be characterised as an international transaction; the AMP base also had to exclude selling and related expenses, and the subsidy component, with the benchmarking exercise sent back for fresh examination. Unutilized subsidy received for specified advertisement and sales promotion purposes was not taxable on receipt, because the unspent amount remained a liability until actually applied and every receipt is not income. Claims for prepaid taxes, foreign tax credit, brought forward losses, Chapter VI-A deduction and section 234B interest also required fresh verification, with remand after hearing the assessee. en-us Tue, 21 Aug 2018 00:00:00 +0530 Fri, 24 Aug 2018 11:51:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=366404 Transfer pricing treatment of AMP spend required verification of the contractual framework before it could be characterised as an international transaction; the AMP base also had to exclude selling and related expenses, and the subsidy component, with the benchmarking exercise sent back for fresh examination. Unutilized subsidy received for specified advertisement and sales promotion purposes was not taxable on receipt, because the unspent amount remained a liability until actually applied and every receipt is not income. Claims for prepaid taxes, foreign tax credit, brought forward losses, Chapter VI-A deduction and section 234B interest also required fresh verification, with remand after hearing the assessee. Case-Laws Income Tax Tue, 21 Aug 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=366404