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2014 (6) TMI 565 - ITAT DELHITransfer pricing adjustment – Advertisement, marketing and sales promotion expenses - LG. Electronics India P. Ltd. Versus Assistant Commissioner of Income-tax [2013 (6) TMI 217 - ITAT DELHI] not followed – Held that:- Incurrence of AMP expenses higher than those incurred by comparable companies resulted in creation of marketing intangibles for the AE, thus amounting to an international transaction - Expenditure on Selling and distribution, being in the nature of selling expenses had to be excluded from the ambit of AMP expenses - DRP does not appear to have recorded categorical findings - apart assessee’s pleas on comparables are not found to have been considered objectively – thus the order of the AA is set aside and the matter is remitted back to the Assessing Authority for fresh adjudication – Decided in favour of Assessee.
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