https://www.taxtmi.com/caselaws?id=443119 TP adjustment on AMP spend was rejected because absent evidence of an arrangement to incur AMP on behalf of the AE, a notional/indirect brand benefit is not an "international transaction" under Ch. X; the AMP adjustment was deleted. TP adjustment on royalty was covered by prior year findings under the same agreement and was deleted. TP adjustments on regional and global service fees were held unsustainable as the TPO determined ALP on ad hoc salary/man-hour estimates without applying a method under s.92C(1); both adjustments were deleted. Under s.14A r/w r.8D, no interest disallowance lay due to sufficient own funds; verification of direct/indirect expenses was remanded. Forex loss on cancelled forward contracts was treated as business loss and allowed. Deduction u/s 80-IC was allowed; AIR-based addition was deleted; MAT credit and s.234C interest were remanded; s.234A interest was deleted. en-us Mon, 31 Jul 2023 00:00:00 +0530 Mon, 05 Jan 2026 11:28:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=443119 TP adjustment on AMP spend was rejected because absent evidence of an arrangement to incur AMP on behalf of the AE, a notional/indirect brand benefit is not an "international transaction" under Ch. X; the AMP adjustment was deleted. TP adjustment on royalty was covered by prior year findings under the same agreement and was deleted. TP adjustments on regional and global service fees were held unsustainable as the TPO determined ALP on ad hoc salary/man-hour estimates without applying a method under s.92C(1); both adjustments were deleted. Under s.14A r/w r.8D, no interest disallowance lay due to sufficient own funds; verification of direct/indirect expenses was remanded. Forex loss on cancelled forward contracts was treated as business loss and allowed. Deduction u/s 80-IC was allowed; AIR-based addition was deleted; MAT credit and s.234C interest were remanded; s.234A interest was deleted. Case-Laws Income Tax Mon, 31 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=443119