Shift in Business Model Justified – ITAT Allows ₹15.22 Cr Compensation & Strikes Down AMP TP Adjustment

Tupperware India Private Limited Vs National Faceless Assessment Centre (ITAT Delhi) Tupperware India Private Limited Vs National Faceless Assessment Centre Tupperware India shifted from its long-standing Direct Selling Model to an Omni-Channel model that included retail &  e-commerce. This change adversely affected its existing distributors, &  to retain them &  avoid disputes, the company paid a one-time compensation of ₹15.22 crore. AO disallowed the payment, but ITAT held that the expenditure was incurred out of commercial necessity, did not create any capital asset, &...