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2015 (9) TMI 484 - ITAT DELHITransfer Pricing adjustment - TPO/AO/DRP held that advertising, marketing and promotional (“AMP”) expenditure as a separate international transaction under Section 92B - Held that:- TP issue on the same facts and circumstances i.e., AMP expenses, arose in the case of the assessee in the preceding year i.e. AY 2008-09 which has been set aside and restored to the file of the Assessing Officer to decide the same afresh in view of the Special Bench judgment of ITAT in the case of LG Electronics (2013 (6) TMI 217 - ITAT DELHI) - Decided in favour of assessee for statistical purposes. Disallowance of 10 percent of total advertisement and selling expenses on the ground that it resulted in enduring benefit to the appellant, and was, thus, capital in nature - Held that:- Since the corporate tax addition has direct connection with the TP addition inasmuch as it is claimed that because of the TP adjustment it is claimed to be double disallowance, this issue is also restored to the file of the Assessing Officer for deciding the same afresh in the light of TP addition and Hon’ble High Court judgment in the case of associated concern i.e. Sony India P.Ltd.[2012 (2) TMI 493 - DELHI HIGH COURT]- Decided in favour of assessee for statistical purposes.
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