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2015 (10) TMI 1373 - ITAT DELHITransfer Pricing Adjustment on account of AMP expenses - Held that:- We agree in principle with the contention that the expenses directly connected with sales should be excluded. The Special Bench in LG Electronics (2013 (6) TMI 217 - ITAT DELHI) has specifically dealt with this issue and held that the dealers commission and sales commission etc. are in the nature of the expenses directly connected with sales and hence should not be included within the overall AMP expenses for processing them u/s 92 of the Act. Since, such detail is not available on record, we direct the A.O/TPO to examine the detail of total AMP expenses and exclude such sales specific expenses in line with the decision of LG Electronics for working out the remaining amount to be considered for proceeding with the AMP expenses under the TP provisions. We therefore, set aside the impugned order and remit the matter to the file of the AO / TPO to decide this issue afresh in conformity with the Special Bench decision in the case of LG Electronics (Supra). - Decided in favour of assessee for statistical purposes.
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