https://www.taxtmi.com/caselaws?id=465926 Addresses transfer pricing scrutiny of AMP expenditure as alleged enhancement of AE marketing intangibles, noting prior ITAT rulings favouring the assessee and treating such AMP charges as a distinct international transaction where compensation may be required; directs exclusion of listed companies with current turnover above Rs.200 crore from comparable set and excludes a specific company for lack of functional comparability and segmental data; and considers disallowance of seminars and sales promotion under MCI/CBDT guidance, remitting assessment to AO for granular evaluation of nexus and contractual obligations in light of higher court dictum. en-us Wed, 29 Mar 2023 00:00:00 +0530 Thu, 15 Jan 2026 18:59:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465926 Addresses transfer pricing scrutiny of AMP expenditure as alleged enhancement of AE marketing intangibles, noting prior ITAT rulings favouring the assessee and treating such AMP charges as a distinct international transaction where compensation may be required; directs exclusion of listed companies with current turnover above Rs.200 crore from comparable set and excludes a specific company for lack of functional comparability and segmental data; and considers disallowance of seminars and sales promotion under MCI/CBDT guidance, remitting assessment to AO for granular evaluation of nexus and contractual obligations in light of higher court dictum. Case-Laws Income Tax Wed, 29 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465926