https://www.taxtmi.com/caselaws?id=758876 The ITAT Delhi ruled on multiple transfer pricing and depreciation issues. Regarding AMP expenses, the tribunal held that separate AMP adjustment is unnecessary when distribution business is already benchmarked using TNM method and found within ALP. Following HC precedent in Maruti Suzuki case, the tribunal rejected TPO's approach of benchmarking AMP expenses separately using BLT method. For reimbursement of marketing expenses, considering time elapsed and to resolve the long-pending issue, the tribunal directed 20% addition to reimbursement expenses as ALP adjustment rather than remitting back to AO/TPO. The appeal was partly allowed with directions for completing benchmarking of international transactions. en-us Fri, 30 Aug 2024 00:00:00 +0530 Thu, 19 Sep 2024 16:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=758876 The ITAT Delhi ruled on multiple transfer pricing and depreciation issues. Regarding AMP expenses, the tribunal held that separate AMP adjustment is unnecessary when distribution business is already benchmarked using TNM method and found within ALP. Following HC precedent in Maruti Suzuki case, the tribunal rejected TPO's approach of benchmarking AMP expenses separately using BLT method. For reimbursement of marketing expenses, considering time elapsed and to resolve the long-pending issue, the tribunal directed 20% addition to reimbursement expenses as ALP adjustment rather than remitting back to AO/TPO. The appeal was partly allowed with directions for completing benchmarking of international transactions. Case-Laws Income Tax Fri, 30 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=758876