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2018 (5) TMI 159 - KARNATAKA HIGH COURTTransfer Pricing Adjustment made on account of the expenditure towards Advertisement, Marketing and Promotion (AMP ) - Stay against demand - Held that:- As against the impugned demand of ₹ 22.17 crores, the Tribunal granted the stay with deposit of ₹ 2 crores in addition to ₹ 3.32 crores; and looking to the issues involved, as regards expenditure towards AMP, it is difficult to deduce that the writ petition was filed in an entirely irresponsible manner or that the authorities should be penalized in monetary terms on that count. In the totality of circumstances, we do not find it necessary to dilate further in this matter. In our view, interest of justice shall be served with the clarification that the observations occurring in the order impugned would only be considered as being relevant for the purpose of the consideration of the matter for interim relief and by waiving the costs imposed. It would, however, be expected of the authorities concerned to take necessary steps so as to guard against filing of frivolous petitions, as indicated and observed by the learned Single Judge.
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