https://www.taxtmi.com/caselaws?id=384162 The Tribunal ruled in favor of the assessee on various grounds including transfer pricing adjustments, AMP expenditure, disallowance under Section 40(a)(i), and set-off of brought forward losses. The Tribunal directed the AO/TPO to comply with the DRP's directions on transfer pricing adjustments and reconsider the AMP adjustment. It was held that AMP expenses primarily benefit the assessee in India and do not constitute an international transaction. The disallowance under Section 40(a)(i) was not warranted, and the Tribunal directed the AO to allow the claim for set-off of brought forward losses. Penalty proceedings under Section 271(1)(c) were dismissed as premature. en-us Wed, 31 Jul 2019 00:00:00 +0530 Tue, 06 Aug 2019 16:27:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=384162 The Tribunal ruled in favor of the assessee on various grounds including transfer pricing adjustments, AMP expenditure, disallowance under Section 40(a)(i), and set-off of brought forward losses. The Tribunal directed the AO/TPO to comply with the DRP's directions on transfer pricing adjustments and reconsider the AMP adjustment. It was held that AMP expenses primarily benefit the assessee in India and do not constitute an international transaction. The disallowance under Section 40(a)(i) was not warranted, and the Tribunal directed the AO to allow the claim for set-off of brought forward losses. Penalty proceedings under Section 271(1)(c) were dismissed as premature. Case-Laws Income Tax Wed, 31 Jul 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=384162