Home Highlights June 2013 Year 2013 This

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1. Valuation - agreement with dealers for sales promotion - advertisement expenses - the advertisement expenses recovered from the dealers would not be includible in the...

2. TP Adjustment - adjustment made on account of advertisement, marketing and promotion (AMP) expenses - internatinal transaction - the AMP expenditure incurred by the...

3. Service tax - reimbursement of advertisement expenses and other sales promotion expenses - since expenses reimbursed on actual basis for achieving the Sales target,...

4. Sales promotion expenses - expenditure with respect to the gold chains being distributed - expenditure allowed - AT

5. Advertisement and marketing expenses – Trading expenses or not - very year, the assessee has been incurring substantial expenditure on advertisements - It is an...

6. TP Adjustment - AMP expenses by applying bright line test on protective basis - TP adjustment amounting by applying BLT is not sustainable on protective basis having no...

7. Adjustment of arm's length price - There is no reason to change the head of expenses from advertisement expenditure to business promotion expenditure - AT

8. TP Adjustment - Naturally when sales price consists of price for warranty and After sales services, which are promised at the time of sales, naturally corresponding...

9. TP Adjustment - apportioning the expenses of assessee’s affiliates - Also noted that the assessee has received certain services from its AE which has been treated by the...

10. TP adjustment - scope of TP adjustment when assessee is eligible for exemption u/s 10B - Irrespective of profit making ability and exemption available in the country of...

11. Valuation - inclusion in taxable services or not - expense incurred by the agents, namely, travel, conveyance and vehicle running expenses, training expenses, printing...

12. TP adjustment on account of reimbursement of seafarer expenses - Revenue has only doubted the genuineness of the alleged reimbursement of expenses made by the assessee...

13. TP Adjustment - in case if a TP adjustment is allowed in respect of transactions entered into by the assessee with unrelated third parties then the same would be result...

14. TP Adjustment - MAM selection - A categorical finding was given that the advertisement publicity and business development expenses are not at all related to the...

15. Addition on account of Business Promotion Expenses - personal element in the business promotion expenses to the extent of 10% of the total expenses cannot be ruled out.