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    <title>Cost-to-cost reimbursements for AE&#039;s marketing events and year-end service provisions: no TP mark-up, adjustment deleted; 115JB recompute</title>
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    <description>Reimbursements paid by the assessee to third-party vendors for marketing events organized for its AE, and recovered on a cost-to-cost basis, were held not to constitute an international transaction involving services, as the assessee merely facilitated payments without value addition; consequently, no separate mark-up could be imputed and the TP adjustment was deleted. Year-end provisions for installation/authorised services and sales commission were held allowable if not ad hoc and reversed in the immediately succeeding year; the installation/authorised services provision was remanded for AO verification of a scientific basis and, if proved, to be allowed. Book profits under section 115JB and interest were directed to be recomputed/verified as per law. - ITAT</description>
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    <pubDate>Fri, 26 Dec 2025 07:18:36 +0530</pubDate>
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      <title>Cost-to-cost reimbursements for AE&#039;s marketing events and year-end service provisions: no TP mark-up, adjustment deleted; 115JB recompute</title>
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      <description>Reimbursements paid by the assessee to third-party vendors for marketing events organized for its AE, and recovered on a cost-to-cost basis, were held not to constitute an international transaction involving services, as the assessee merely facilitated payments without value addition; consequently, no separate mark-up could be imputed and the TP adjustment was deleted. Year-end provisions for installation/authorised services and sales commission were held allowable if not ad hoc and reversed in the immediately succeeding year; the installation/authorised services provision was remanded for AO verification of a scientific basis and, if proved, to be allowed. Book profits under section 115JB and interest were directed to be recomputed/verified as per law. - ITAT</description>
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