https://www.taxtmi.com/caselaws?id=768218 ITAT Mumbai allowed the assessee's appeal in a transfer pricing dispute involving royalty payments and AMP expenditure. The court held that TP adjustments for royalty payments to related parties for trademark usage should be remanded to TPO for proper examination using internal CUP method, or alternatively accepted at 5.20% arm's length rate. Regarding AMP expenditure, the tribunal deleted the adjustment, ruling that expenses were integral to business operations and could not be arbitrarily segregated as brand promotion for associated enterprises, rejecting the TPO's characterization of assessee as mere distributor. en-us Wed, 12 Feb 2025 00:00:00 +0530 Tue, 01 Apr 2025 14:19:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=768218 ITAT Mumbai allowed the assessee's appeal in a transfer pricing dispute involving royalty payments and AMP expenditure. The court held that TP adjustments for royalty payments to related parties for trademark usage should be remanded to TPO for proper examination using internal CUP method, or alternatively accepted at 5.20% arm's length rate. Regarding AMP expenditure, the tribunal deleted the adjustment, ruling that expenses were integral to business operations and could not be arbitrarily segregated as brand promotion for associated enterprises, rejecting the TPO's characterization of assessee as mere distributor. Case-Laws Income Tax Wed, 12 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=768218