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2018 (1) TMI 1473 - AT - Income TaxTransfer pricing adjustment - ALP determination - international transactions - expenses incurred by the assessee towards advertisement and sales promotion expenses as helping the promotion of "Renault" brand in India - HELD THAT:- Just because assessee mentioned that marketing expenditure incurred by it helped promotion of Renault brand in India, it cannot be presumed that such expenditure resulted in any ‘’international transaction. Expenditure was incurred by the assessee, to create market share for its Cars and marginal benefits derived by its principal abroad, as an off shoot cannot in our opinion convert it to a international transaction. See MARUTI SUZUKI INDIA LTD. VERSUS COMMISSIONER OF INCOME TAX [2015 (12) TMI 634 - DELHI HIGH COURT] - Decided in favour of assessee.
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