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    <title>2020 (1) TMI 774 - ITAT DELHI</title>
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    <description>The Tribunal concluded that the Resale Price Method (RPM) was the most appropriate method for benchmarking international transactions due to the lack of value addition by the assessee. It directed the Assessing Officer to apply RPM in the distribution segment. Additionally, the Tribunal ruled that Advertising, Marketing, and Promotion (AMP) expenses were domestic transactions not subject to transfer pricing regulations, leading to the deletion of related adjustments. The Tribunal upheld the inclusion of subvention income as operating income but dismissed the appeal on corporate issues for lack of evidence. The Revenue&#039;s appeal was also dismissed as consequential to the assessee&#039;s appeal.</description>
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      <link>https://www.taxtmi.com/caselaws?id=391161</link>
      <description>The Tribunal concluded that the Resale Price Method (RPM) was the most appropriate method for benchmarking international transactions due to the lack of value addition by the assessee. It directed the Assessing Officer to apply RPM in the distribution segment. Additionally, the Tribunal ruled that Advertising, Marketing, and Promotion (AMP) expenses were domestic transactions not subject to transfer pricing regulations, leading to the deletion of related adjustments. The Tribunal upheld the inclusion of subvention income as operating income but dismissed the appeal on corporate issues for lack of evidence. The Revenue&#039;s appeal was also dismissed as consequential to the assessee&#039;s appeal.</description>
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