https://www.taxtmi.com/caselaws?id=394119 The Tribunal ruled in favor of the appellant regarding the adjustment on account of Advertisement, Marketing, and Promotion (AMP) expenses, stating that no Transfer Pricing (TP) adjustment could be made without evidence of an agreement with Associated Enterprises (AEs). The Tribunal also rejected the application of the bright line method for benchmarking AMP expenses. The matter of adjustment on import of finished goods was remanded back for further examination to consider the overseas AE as the tested party. Other issues, including levying interest under section 234B, set-off of assessed loss, taxation of royalty provision reversal, short credit of TDS, and recovery of allegedly granted refund, were also remanded back to the Dispute Resolution Panel for reconsideration and appropriate action. en-us Tue, 03 Mar 2020 00:00:00 +0530 Wed, 01 Apr 2020 15:42:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=394119 The Tribunal ruled in favor of the appellant regarding the adjustment on account of Advertisement, Marketing, and Promotion (AMP) expenses, stating that no Transfer Pricing (TP) adjustment could be made without evidence of an agreement with Associated Enterprises (AEs). The Tribunal also rejected the application of the bright line method for benchmarking AMP expenses. The matter of adjustment on import of finished goods was remanded back for further examination to consider the overseas AE as the tested party. Other issues, including levying interest under section 234B, set-off of assessed loss, taxation of royalty provision reversal, short credit of TDS, and recovery of allegedly granted refund, were also remanded back to the Dispute Resolution Panel for reconsideration and appropriate action. Case-Laws Income Tax Tue, 03 Mar 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=394119