https://www.taxtmi.com/caselaws?id=769528 Commission paid to local distributors was wrongly treated as part of AMP expenditure to compute a TP adjustment. Applying the consistency principle and prior judicial precedents, the ITAT held that such commission is not AMP expenditure and that AMP expenses (including distributor commission) do not constitute an "international transaction"; consequently, the AMP adjustment/addition made by the TPO/AO/DRP was deleted. On deduction under s. 80G for amounts forming part of CSR spend, the ITAT held that Expln. 2 to s. 37 bars CSR only as business expenditure computation and cannot deny an otherwise eligible s. 80G deduction; accordingly, s. 80G deduction was allowed. Where s. 80G was disallowed solely for non-production of donation receipts, the issue was remanded to the AO for verification and allowance to the extent eligible. en-us Wed, 23 Apr 2025 00:00:00 +0530 Tue, 30 Dec 2025 17:48:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=769528 Commission paid to local distributors was wrongly treated as part of AMP expenditure to compute a TP adjustment. Applying the consistency principle and prior judicial precedents, the ITAT held that such commission is not AMP expenditure and that AMP expenses (including distributor commission) do not constitute an "international transaction"; consequently, the AMP adjustment/addition made by the TPO/AO/DRP was deleted. On deduction under s. 80G for amounts forming part of CSR spend, the ITAT held that Expln. 2 to s. 37 bars CSR only as business expenditure computation and cannot deny an otherwise eligible s. 80G deduction; accordingly, s. 80G deduction was allowed. Where s. 80G was disallowed solely for non-production of donation receipts, the issue was remanded to the AO for verification and allowance to the extent eligible. Case-Laws Income Tax Wed, 23 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=769528