https://www.taxtmi.com/caselaws?id=459451 ITAT Delhi held that direct marketing and sales-related expenses including rebates and discounts cannot be included in Advertisement, Marketing and Promotion (AMP) expenses for transfer pricing purposes, following Sony Ericsson precedent. After excluding Rs.22.64 crores of rebate/discount from AMP expenses, the arm's length price was determined at Rs.26.31 crores with 9% markup. Since the grant received from associated enterprise (Rs.27.23 crores) exceeded the arm's length price, no transfer pricing adjustment was warranted. The addition of Rs.11.46 crores made by Assessing Officer was deleted. Assessee's appeal allowed partially. en-us Mon, 03 Dec 2018 00:00:00 +0530 Fri, 13 Dec 2024 19:06:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=459451 ITAT Delhi held that direct marketing and sales-related expenses including rebates and discounts cannot be included in Advertisement, Marketing and Promotion (AMP) expenses for transfer pricing purposes, following Sony Ericsson precedent. After excluding Rs.22.64 crores of rebate/discount from AMP expenses, the arm's length price was determined at Rs.26.31 crores with 9% markup. Since the grant received from associated enterprise (Rs.27.23 crores) exceeded the arm's length price, no transfer pricing adjustment was warranted. The addition of Rs.11.46 crores made by Assessing Officer was deleted. Assessee's appeal allowed partially. Case-Laws Income Tax Mon, 03 Dec 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=459451