https://www.taxtmi.com/caselaws?id=457866 ITAT Delhi allowed assessee's appeal regarding trademark fee payment to US Associated Enterprise and advertisement expenditure disallowance. The Tribunal deleted the transfer pricing adjustment on royalty payment, finding the assessee's operating margin of 6.96% exceeded comparables at 2.77%, establishing arm's length pricing under TNMM. Following consistent decisions from previous assessment years, the Tribunal held direct nexus existed between revenue and royalty payments for brand name usage. Additionally, the Tribunal deleted the 30% adhoc disallowance of advertisement expenditure, ruling such expenditure was wholly for business purposes and adhoc disallowances are impermissible under law. en-us Wed, 11 Aug 2021 00:00:00 +0530 Sun, 29 Sep 2024 16:20:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=457866 ITAT Delhi allowed assessee's appeal regarding trademark fee payment to US Associated Enterprise and advertisement expenditure disallowance. The Tribunal deleted the transfer pricing adjustment on royalty payment, finding the assessee's operating margin of 6.96% exceeded comparables at 2.77%, establishing arm's length pricing under TNMM. Following consistent decisions from previous assessment years, the Tribunal held direct nexus existed between revenue and royalty payments for brand name usage. Additionally, the Tribunal deleted the 30% adhoc disallowance of advertisement expenditure, ruling such expenditure was wholly for business purposes and adhoc disallowances are impermissible under law. Case-Laws Income Tax Wed, 11 Aug 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=457866