https://www.taxtmi.com/caselaws?id=412734 The Tribunal dismissed the Revenue's appeal, upholding the Ld. CIT(A)'s order regarding the deletion of the AMP adjustment. The main issues revolved around the aggregation of AMP activities with other international transactions, appropriateness of commission as remuneration for services, separate benchmarking for brand building, benchmarking compensation for AMP services, consistency in transfer pricing adjustments, and jurisdiction of the assessee as a distributor or manufacturer. The Ld. CIT(A) emphasized the principle of consistency and rejected the TPO's approach, leading to the deletion of the transfer pricing addition for AMP expenses. en-us Fri, 17 Sep 2021 00:00:00 +0530 Sat, 25 Sep 2021 09:35:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=412734 The Tribunal dismissed the Revenue's appeal, upholding the Ld. CIT(A)'s order regarding the deletion of the AMP adjustment. The main issues revolved around the aggregation of AMP activities with other international transactions, appropriateness of commission as remuneration for services, separate benchmarking for brand building, benchmarking compensation for AMP services, consistency in transfer pricing adjustments, and jurisdiction of the assessee as a distributor or manufacturer. The Ld. CIT(A) emphasized the principle of consistency and rejected the TPO's approach, leading to the deletion of the transfer pricing addition for AMP expenses. Case-Laws Income Tax Fri, 17 Sep 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=412734