Landmark ITAT Special Bench Verdict On Transfer Pricing Of advertisement, marketing & sales promotion expenses

L.G.Electronics India Pvt. Ltd vs. ACIT (ITAT Delhi Special Bench) Transfer Pricing: The ‘Bright Line test’ can be applied to disallow the excessive advertisement, marketing and sales promotion (AMP) expenses incurred by the assessee for the benefit of the brand owner Transfer pricing adjustment in relation to advertisement, marketing and sales promotion expenses  incurred by the assessee for creating or improving the marketing intangible for and on behalf of the foreign Associated Enterprises is permissible. Earning a mark-up from the Associated Enterprises  in respect of AMP e...