Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2023 (3) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2023 (3) TMI 1022 - AT - Income TaxTP Adjustment - adjustment on account of Advertisement, Marketing and Promotion expenses (AMP expenses) - HELD THAT:- The Co-ordinate Bench of the Tribunal [2018 (12) TMI 111 - ITAT DELHI] held that the there does not exist any international transaction between the assessee and the AE with regard to incurring of AMP expenses. Thus by following the principle of consistency we are of the considered opinion that the adjustment made by the TPO/DRP/A.O by applying BLT on account of AMP expenses in the absence of international transactions between the tax payer and the A.E is not sustainable in the eyes of law. Hence, the same is order to be deleted. Decided in favour of assessee.
|