2018 (7) TMI 1871 - HC - Income Tax

TPA - AMP expenses - Held that - Directions given in paragraph 8 of the impugned order should not be construed as if the AO/Transfer Pricing Officer (TPO) would examine Advertisement Marketing and Sales Promotion (AMP) expenses as a separate international transaction. AMP expenses were part and parcel of the expenses incurred of the distribution. While determining Arms Length Price, the said aspect would be taken into consideration by the Assessing Officer/TPO.

Summary

The Delhi High Court clarified that Advertisement Marketing and Sales Promotion (AMP) expenses should be considered as part of distribution expenses while determining Arms Length Price. The case was re-listed for further proceedings on 5th September, 2018.