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    <title>2020 (1) TMI 861 - ITAT DELHI</title>
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    <description>AMP expenditure did not constitute an international transaction where no arrangement or undertaking with associated enterprises required its incurrence; the transfer pricing adjustment was deleted. Local sales-promotion expenditure remained deductible as business expenditure despite incidental benefit to an overseas group, and the alternative AMP disallowance was deleted. Research and development outlay denied weighted deduction under the special approval regime remained eligible for normal business deduction under section 37(1). Additions arising from Form 26AS and AIR mismatches, employee-welfare expenditure for employees&#039; daughters&#039; marriages, and foreign tax credit claims required verification of reconciliations, supporting details and withholding certificates, and were restored for factual examination.</description>
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      <link>https://www.taxtmi.com/caselaws?id=391248</link>
      <description>AMP expenditure did not constitute an international transaction where no arrangement or undertaking with associated enterprises required its incurrence; the transfer pricing adjustment was deleted. Local sales-promotion expenditure remained deductible as business expenditure despite incidental benefit to an overseas group, and the alternative AMP disallowance was deleted. Research and development outlay denied weighted deduction under the special approval regime remained eligible for normal business deduction under section 37(1). Additions arising from Form 26AS and AIR mismatches, employee-welfare expenditure for employees&#039; daughters&#039; marriages, and foreign tax credit claims required verification of reconciliations, supporting details and withholding certificates, and were restored for factual examination.</description>
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