https://www.taxtmi.com/caselaws?id=763192 Transfer pricing adjustment for advertising, marketing and promotional expenditure was found unsustainable because no material showed an arrangement or concerted action with the associated enterprise. Disallowance under section 14A was held unjustified where no exempt income had been earned in the relevant years. Brand building expenditure was treated as deductible business expenditure, and a notional disallowance based only on incidental enhancement of the overseas brand was rejected. Disallowance founded on seized material from earlier assessment years also failed because no incriminating material linked to the years under appeal. The assessments were therefore left undisturbed in the assessee's favour. en-us Thu, 29 Aug 2024 00:00:00 +0530 Fri, 13 Dec 2024 20:52:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=763192 Transfer pricing adjustment for advertising, marketing and promotional expenditure was found unsustainable because no material showed an arrangement or concerted action with the associated enterprise. Disallowance under section 14A was held unjustified where no exempt income had been earned in the relevant years. Brand building expenditure was treated as deductible business expenditure, and a notional disallowance based only on incidental enhancement of the overseas brand was rejected. Disallowance founded on seized material from earlier assessment years also failed because no incriminating material linked to the years under appeal. The assessments were therefore left undisturbed in the assessee's favour. Case-Laws Income Tax Thu, 29 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=763192