TP adjustments towards AMP expenditure pertaining to trading ...

Income Tax

September 28, 2022

TP adjustments towards AMP expenditure pertaining to trading segment AND reimbursement of warranty expenses to AE - the AMP expenses and warranty expenses cannot be treated as a separate international transaction when the TPO has not otherwise rejected the margins of the assessee in the trading segment. - AT

View Source

← Previous Next →

TP adjustments towards AMP expenditure pertaining to trading ...

Income Tax

September 28, 2022

You may also like:

TP Adjustment - AMP expenses by applying bright line test on protective basis - TP adjustment amounting by applying BLT is not sustainable on protective basis having no...

TP Adjustment - Addition as ‘Fees for Technical Services’ ignoring the assessee’s contention that it was purely reimbursement received for Construction and Management...

TP adjustment on account of reimbursement of seafarer expenses - Revenue has only doubted the genuineness of the alleged reimbursement of expenses made by the assessee...

TP Adjustment - adjustment on account of AMP - we cannot infer the existence of international transactions qua AMP expenses between taxpayer and AE beyond the...

TP Adjustment - allocate various costs between the ‘Trading’ and ‘Manufacturing’ segments - Despite an opportunity granted by the TPO, the assessee still did not come...

TP Adjustment - adjustment made on account of advertisement, marketing and promotion (AMP) expenses - internatinal transaction - the AMP expenditure incurred by the...

TP Adjustment - international transaction - in the absence of no written agreement exists between the assessee and its AE requiring the assessee to incur AMP expenses,...

TP Adjustment - adjustment on account of AMP expenditure - We are unable to accept the said contention of the learned counsel for the Revenue that since the Assessee...

TPA - AMP expenses - Revenue has not been able to demonstrate that there exists an international transaction involving the Assessee and a foreign AE on the question of...

TP adjustment on account of Travel expenses - when the entire expenditure was incurred for hotel stay and travel of both Mr. Stan Wojicierczk and Mr. Raj Lakhani then...

Quick Updates: