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2018 (7) TMI 1727 - AT - Income TaxTPA - Comparable selection - Held that:- The assessee provides ancillary management services to Six Continents Hotels, Inc. It also renders service to Indian franchises of its foreign affiliates, thus companies functionally dissimilar with that of assessee need to be deselected from final list. Addition on account of project and consultation fee and on account of advertisement and sales promotion - Held that:- As decided in assessee's own case we find that the expenditure on advertisement was in print and electronic media and for hosting / sponsoring certain conventions and conferences and similar other expenditure on calendar printing, posters etc. We note that the total expenditure works out approximately 1.9% of the total expenditure. We are in agreement with the Ld. Commissioner of Income Tax (A) that there is no element of brand building or acquisition of brand by incurring such expenses. The concerned brands were not owned by the assessee, but it belongs to the assessee's overseas group entity, assessee has been reimbursed the entire advertisement and sale promotion expenses by the overseas group entity on cost plus basis. Under the circumstances, we do not find any infirmity in the order of me Ld. Commissioner of Income Tax (A) in holding that these expenses are revenue in nature.
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