https://www.taxtmi.com/caselaws?id=431509 The Tribunal partly allowed the appeal, directing the Transfer Pricing Officer (TPO) to use the Comparable Uncontrolled Price (CUP) method for the manufacturing segment and reconsider the Arm's Length Price (ALP) for Advertising, Marketing & Promotion (AMP) expenses using the net profit margin method. The provision for warranty was deemed allowable, and the disallowance of advertisement expenditure was overturned. The Tribunal dismissed the initiation of Section 271(1)(c) of the Act as it was incidental to the main issues. en-us Mon, 13 Jun 2022 00:00:00 +0530 Wed, 14 Dec 2022 10:25:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=431509 The Tribunal partly allowed the appeal, directing the Transfer Pricing Officer (TPO) to use the Comparable Uncontrolled Price (CUP) method for the manufacturing segment and reconsider the Arm's Length Price (ALP) for Advertising, Marketing & Promotion (AMP) expenses using the net profit margin method. The provision for warranty was deemed allowable, and the disallowance of advertisement expenditure was overturned. The Tribunal dismissed the initiation of Section 271(1)(c) of the Act as it was incidental to the main issues. Case-Laws Income Tax Mon, 13 Jun 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=431509