https://www.taxtmi.com/caselaws?id=375168 AMP expenditure could not be benchmarked independently without first verifying whether the agreements created an international transaction and how the AMP arrangement operated. Sales-related expenditure and subsidy were directed to be excluded from the AMP base, while business promotion expenses required fresh examination on the record. Reimbursement of salary paid to seconded employees could not be conclusively treated as fees for technical services on the existing material because the secondment agreement was not before the Tribunal, so the withholding-tax and section 40(a)(i) question had to be rechecked. TDS credit was also left for verification, with interest consequential and penalty premature. en-us Mon, 11 Feb 2019 00:00:00 +0530 Fri, 15 Feb 2019 08:09:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=375168 AMP expenditure could not be benchmarked independently without first verifying whether the agreements created an international transaction and how the AMP arrangement operated. Sales-related expenditure and subsidy were directed to be excluded from the AMP base, while business promotion expenses required fresh examination on the record. Reimbursement of salary paid to seconded employees could not be conclusively treated as fees for technical services on the existing material because the secondment agreement was not before the Tribunal, so the withholding-tax and section 40(a)(i) question had to be rechecked. TDS credit was also left for verification, with interest consequential and penalty premature. Case-Laws Income Tax Mon, 11 Feb 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=375168