Section 14A Amendment Not Retrospective & AMP Adjustment Not an International Transaction: Delhi HC

PCIT Vs Amadeus India Pvt. Ltd (Delhi High Court) This Revenue appeal u/s 260A challenged the ITAT Delhi order dated 10.01.2025 in ITA No.1656/Del/ 2022, wherein Tribunal had allowed Amadeus India Pvt. Ltd.’s appeal for AY 2018-19. The High Court condoned a brief delay of 18 days in filing & 17 days in re-filing before proceeding to hear the matter. Issue-1: AMP Expenditure – Transfer Pricing Adjustment Revenue’s counsel candidly admitted that the issue of Advertising, Marketing & Promotion (AMP) expenses stood covered against Revenue & in favour of Assessee by Delhi HC’s e...