https://www.taxtmi.com/caselaws?id=767603 ITAT Delhi held in favor of assessee on AMP expenses, ruling that quantum alone cannot establish benefit to foreign AE's brand without demonstrating expenses were for brand enhancement beyond local market rather than local market penetration. On royalty payments, tribunal found TPO's rejection of assessee's comparable agreements unjustified as they belonged to same industry. Management service fee and interest on receivables issues were remitted to AO for fresh examination following coordinate bench directions and working capital adjustments. Payment to Dart issue restored to AO/TPO based on precedent from assessee's own case for AY 2013-14. en-us Wed, 12 Mar 2025 00:00:00 +0530 Fri, 21 Mar 2025 08:25:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767603 ITAT Delhi held in favor of assessee on AMP expenses, ruling that quantum alone cannot establish benefit to foreign AE's brand without demonstrating expenses were for brand enhancement beyond local market rather than local market penetration. On royalty payments, tribunal found TPO's rejection of assessee's comparable agreements unjustified as they belonged to same industry. Management service fee and interest on receivables issues were remitted to AO for fresh examination following coordinate bench directions and working capital adjustments. Payment to Dart issue restored to AO/TPO based on precedent from assessee's own case for AY 2013-14. Case-Laws Income Tax Wed, 12 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767603