https://www.taxtmi.com/caselaws?id=765778 AMP expenditure could not be treated as an international transaction under Chapter X without evidence of any arrangement, understanding, or concerted action between the assessee and its associated enterprise for brand promotion of the foreign entity; on the facts, the Tribunal followed its earlier orders and deleted the transfer pricing adjustment. The claim for benefit under Article 11 of the India-France DTAA in relation to dividend tax and the connected refund also failed, because the treaty was held not to apply to dividend distribution tax paid by a domestic company under section 115-O and the point had already been decided against the assessee in binding precedent. en-us Mon, 16 Dec 2024 00:00:00 +0530 Mon, 10 Feb 2025 07:50:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=765778 AMP expenditure could not be treated as an international transaction under Chapter X without evidence of any arrangement, understanding, or concerted action between the assessee and its associated enterprise for brand promotion of the foreign entity; on the facts, the Tribunal followed its earlier orders and deleted the transfer pricing adjustment. The claim for benefit under Article 11 of the India-France DTAA in relation to dividend tax and the connected refund also failed, because the treaty was held not to apply to dividend distribution tax paid by a domestic company under section 115-O and the point had already been decided against the assessee in binding precedent. Case-Laws Income Tax Mon, 16 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=765778