https://www.taxtmi.com/caselaws?id=290086 AMP expenditure was treated as an international transaction only where an arrangement or understanding showed that the assessee was obliged to incur the spend for the associated enterprise; incidental benefit to the foreign brand owner was insufficient. The Revenue's reliance on joint venture clauses did not establish any entrustment of brand promotion liability: the clause requiring marketing of licensed products in India reflected a normal sales function for the assessee's own products, and the trademark clause merely acknowledged the associated enterprise's ownership of the mark and contemplated a separate agreement to preserve that ownership. No mistake apparent from the record was shown, so rectification was refused and the earlier deletion of the transfer pricing adjustment remained undisturbed. en-us Thu, 28 Dec 2017 00:00:00 +0530 Tue, 08 Sep 2020 19:30:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=290086 AMP expenditure was treated as an international transaction only where an arrangement or understanding showed that the assessee was obliged to incur the spend for the associated enterprise; incidental benefit to the foreign brand owner was insufficient. The Revenue's reliance on joint venture clauses did not establish any entrustment of brand promotion liability: the clause requiring marketing of licensed products in India reflected a normal sales function for the assessee's own products, and the trademark clause merely acknowledged the associated enterprise's ownership of the mark and contemplated a separate agreement to preserve that ownership. No mistake apparent from the record was shown, so rectification was refused and the earlier deletion of the transfer pricing adjustment remained undisturbed. Case-Laws Income Tax Thu, 28 Dec 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=290086