2021 (5) TMI 1053 - AT - Income Tax

TP adjustment on account of AMP expenses - expenditure incurred by the assessee for promoting brand and creating marketing intangible of Amadeus Global. - HELD THAT:- We find that identical issue arose in assessee’s own case in earlier years and while deciding the issue [2021 (5) TMI 536 - ITAT DELHI] wherein direct the Assessing Officer /TPO to delete the additions made on account of AMP expenditure, substantive and protective.

Revenue could not point out any distinguishing feature in the facts of the case in the year under consideration and that of the earlier year. We therefore following the order of Co-ordinate Bench in assessee’s own case for earlier years and for similar reasons, direct the AO to delete the addition made on account of AMP expenditure on Substantive protective basis. Thus the ground of the assessee are allowed.