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2017 (7) TMI 1188 - HC - Income TaxAddition being adjustment on account of compensation to be received by the assessee from its Associated Enterprise (AE) for creating marketing intangibles and promoting the brand name of its AE - AMP expenses - Held that:- Tribunal while considering the expenses of the associated enterprise (AE) for creating marketing intangibles and promoting the brand name of its AE, it is for the marketing people to look new products which has competition in the national level or grass route level and International level. It is always for the Company to decide on what ratio the expenses are to be incurred at grass route and on that ratio for promoting their product. In that view of the matter, unless the amount which was found to be not genuine merely because excess amount has been spent on advertisement, will not not be a ground for disallowing the expenses. Decided in favour of assessee Adjustment made on account of Arm’s Length interest to be charged by the assessee on the outstanding receivables from its AEs - Held that:- As relying on Indo American Jewellery [2013 (1) TMI 804 - BOMBAY HIGH COURT] there is complete uniformity in the act of the apellant in not charging interest from both AE’s and non-AEs and adjustment in realization to notional interest on outstanding receivable cannot be made.
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