https://www.taxtmi.com/caselaws?id=285343 The Tribunal ruled in favor of the taxpayer, allowing the appeals in part. It held that the Resale Price Method (RPM) should be used as the Most Appropriate Method (MAM) for benchmarking international transactions, emphasizing the taxpayer's role as a distributor despite additional functions. The Tribunal remanded the issue of Adjustment on Advertisement, Marketing, and Promotion (AMP) Expenses back to the Transfer Pricing Officer (TPO) for reconsideration, citing a lack of opportunity for the taxpayer to be heard. Penalty proceedings and interest charges were deemed premature and not requiring specific adjudication at that stage. en-us Tue, 03 Jul 2018 00:00:00 +0530 Thu, 09 Jan 2020 09:33:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=285343 The Tribunal ruled in favor of the taxpayer, allowing the appeals in part. It held that the Resale Price Method (RPM) should be used as the Most Appropriate Method (MAM) for benchmarking international transactions, emphasizing the taxpayer's role as a distributor despite additional functions. The Tribunal remanded the issue of Adjustment on Advertisement, Marketing, and Promotion (AMP) Expenses back to the Transfer Pricing Officer (TPO) for reconsideration, citing a lack of opportunity for the taxpayer to be heard. Penalty proceedings and interest charges were deemed premature and not requiring specific adjudication at that stage. Case-Laws Income Tax Tue, 03 Jul 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=285343