https://www.taxtmi.com/caselaws?id=796071 Advertisement, marketing and sales-promotion expenditure was treated as commercially expedient where increased beverage sales increased demand for concentrates, with any benefit to bottlers or brand owners being incidental. Marketing-support rebates, discounts, service charges and reimbursements were similarly described as wholly and exclusively connected with the concentrate business. Depreciation on coolers was considered allowable where the assessee retained ownership and control and the coolers supported beverage sales linked to concentrate demand. The transfer-pricing adjustment for advertising, marketing and promotion expenditure was described as unsustainable because the proposed mark-up did not arise from a recognised transfer-pricing method and overall profitability compensated the relevant functions. Consistent earlier decisions on materially identical facts were to be followed absent distinguishing material. en-us Thu, 30 Apr 2026 00:00:00 +0530 Fri, 31 Jul 2026 08:27:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796071 Advertisement, marketing and sales-promotion expenditure was treated as commercially expedient where increased beverage sales increased demand for concentrates, with any benefit to bottlers or brand owners being incidental. Marketing-support rebates, discounts, service charges and reimbursements were similarly described as wholly and exclusively connected with the concentrate business. Depreciation on coolers was considered allowable where the assessee retained ownership and control and the coolers supported beverage sales linked to concentrate demand. The transfer-pricing adjustment for advertising, marketing and promotion expenditure was described as unsustainable because the proposed mark-up did not arise from a recognised transfer-pricing method and overall profitability compensated the relevant functions. Consistent earlier decisions on materially identical facts were to be followed absent distinguishing material. Case-Laws Income Tax Thu, 30 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796071