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    <title>2023 (12) TMI 721 - DELHI HIGH COURT</title>
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    <description>Delhi HC dismissed revenue&#039;s appeal regarding transfer pricing adjustment on advertising, marketing and promotion expenses. The assessee, engaged in import and distribution of products, incurred AMP expenses of Rs. 119.54 crores and received compensation through higher profitability. The court held no upward adjustment was warranted as chosen comparables had lower net margins than assessee. Additionally, TPO&#039;s application of bright line test in determining arm&#039;s length price was legally erroneous. The Tribunal&#039;s order was upheld as no substantial question of law arose.</description>
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      <title>2023 (12) TMI 721 - DELHI HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=447037</link>
      <description>Delhi HC dismissed revenue&#039;s appeal regarding transfer pricing adjustment on advertising, marketing and promotion expenses. The assessee, engaged in import and distribution of products, incurred AMP expenses of Rs. 119.54 crores and received compensation through higher profitability. The court held no upward adjustment was warranted as chosen comparables had lower net margins than assessee. Additionally, TPO&#039;s application of bright line test in determining arm&#039;s length price was legally erroneous. The Tribunal&#039;s order was upheld as no substantial question of law arose.</description>
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      <pubDate>Wed, 13 Dec 2023 00:00:00 +0530</pubDate>
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