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No TP adjustment if AMP exp. was incurred without entering into any agreement with PepsiCo

December 5, 2018[2018] 100 159 (Delhi - Trib.)

IT/ILT: In absence of an agreement or arrangement between assessee a full-fledged manufacturer of soft drinks and AE, for incurring AMP expenses, spending of AMP expenditure by assessee could not be held to be an international transaction between assessee and its AE and accordingly AMP adjustment made by TPO/Assessing Officer would not be sustainable

IT/ILT: Where there was complete uniformity in act of assessee in not charging interest from both AE and non-AE debtors for delay in realization of export proceeds, no adjustment on account of notional interest was warranted

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