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2020 (10) TMI 924 - AT - Income TaxTP Adjustment - adjustment to arm’s length price in respect of AMP expenditure - whether Advertising, Marketing and Promotion (AMP) expenditure could be construed as an international transaction? - HELD THAT:- As decided in own case [2016 (8) TMI 608 - ITAT MUMBAI] AMP expenditure is not an international transaction and hence, no ALP adjustment could be made thereon. Unabsorbed depreciation carried forward and adjusted in view of Section 32(2) - HELD THAT:- Issue decided in favour of the assessee by the decision of General Motors India Pvt. Ltd. [2012 (8) TMI 714 - GUJARAT HIGH COURT]. Also in case of Times Guarantee Ltd.[2010 (6) TMI 516 - ITAT, MUMBAI] on identical issue, by placing reliance on the decision of CIT vs. Hindustan Unilever Pvt. Ltd. [2016 (7) TMI 1245 - BOMBAY HIGH COURT]and several other Bombay High Court decisions, had dismissed the claim of the revenue - Decided in favour of assessee.
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