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TP Adjustment for AMP Expenditure deleted due to Lack of Brand Promotion Agreement with AE
Case Law Details
- Case Name
- Kellogg India Pvt. Ltd Vs ACIT (ITAT Mumbai)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2018-19
- Courts
- All ITAT, ITAT Mumbai
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Kellogg India Pvt. Ltd Vs ACIT (ITAT Mumbai)
ITAT Mumbai held that there was no express arrangement / agreement between the assessee and the AE for incurring advertisement, marketing and promotional expenses (AMP) to promote the brand of the AE and hence the said transactions would not constitute international transaction relating to AMP expenditure. Thus, TP adjustment deleted.
Facts- The Assessee Company claimed to be a wholly owned subsidiary of Kellogg USA and having principal activity of manufacturing and selling of breakfast cereal products in India and neighboring countries. The Assesse...
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