https://www.taxtmi.com/caselaws?id=429431 Advertisement, marketing and promotion expenditure was not treated as an international transaction under the transfer pricing provisions where no material showed an arrangement or understanding to promote the foreign associated enterprise's brand. The Delhi HC noted that the same issue had already been decided in the assessee's favour in earlier assessment years, that no distinguishable change in facts was shown, and that consistency in tax administration supported the same result. On those facts, the transfer pricing adjustment based on higher AMP spend for the benefit of the foreign enterprise was not sustainable. en-us Tue, 18 Oct 2022 00:00:00 +0530 Mon, 10 Apr 2023 10:14:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=429431 Advertisement, marketing and promotion expenditure was not treated as an international transaction under the transfer pricing provisions where no material showed an arrangement or understanding to promote the foreign associated enterprise's brand. The Delhi HC noted that the same issue had already been decided in the assessee's favour in earlier assessment years, that no distinguishable change in facts was shown, and that consistency in tax administration supported the same result. On those facts, the transfer pricing adjustment based on higher AMP spend for the benefit of the foreign enterprise was not sustainable. Case-Laws Income Tax Tue, 18 Oct 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=429431