AMP Expenses Not an International Transaction Due to MLM Commission Structure: ITAT Delhi

Amway India Enterprises Private Limited Vs DCIT (ITAT Delhi) This appeal before the Income Tax Appellate Tribunal, Delhi Bench arose from a final assessment order dated 28.10.2024 passed under sections 143(3) read with sections 144C(13) and 144B of the Income-tax Act, 1961 for Assessment Year 2021–22. The assessee, a wholly owned subsidiary of its foreign parent, is engaged in manufacturing and selling consumer products through a direct selling, multi-level marketing (MLM) model. The assessee had filed its return declaring income of ₹77.89 crore. The case was selected for scrutiny due to t...