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2023 (10) TMI 1325 - HC - Income TaxTP Adjustment - AMP expenses - International transaction - whether the assessee, which is a wholly owned subsidiary of its AE is required to be compensated AMP expenses incurred by it on behalf of its AE? - Tribunal had concluded that the AMP expenses incurred by the respondent/assessee did not amount to an international transaction as relying on decision of this court passed in Maruti Suzuki India Ltd.[2015 (12) TMI 634 - DELHI HIGH COURT] - HELD THAT:- Given the position and the fact that there has been no change in the circumstances concerning the respondent/assessee (something which has been noted by the Tribunal) according to us, in this matter, the principle of consistency would apply. Therefore, we are not inclined to interfere with the impugned order passed by the Tribunal.
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