Case Law Details
ACIT Vs Mattel Toys (India) Pvt. Ltd. (ITAT Mumbai)
Tribunal in assessee’s own case for the A.Yrs.2008-09 and 2009-10 vide order dated 08/07/2016 already held that AMP expenditure is not an international transaction and hence, no ALP adjustment could be made thereon.
Respectfully following the aforesaid decision of this Tribunal in assessee’s own case, we hold that the AMP expenditure is not an international transaction and hence no adjustment to ALP need to be made thereon. Accordingly, the grounds raised by the assessee in its cross objections are allowed.
FULL TEXT OF THE ITAT JUDGEMENT
This appeal in ITA No.3903/Mum/2016 and CO No.152/Mum/2019 for A.Y.2010-11 arise out of the order by the ld. Commissioner of Income Tax (Appeals)-57, Mumbai in appeal No.CIT(A)-57/Arr.82/2015-16 dated 03/02/2016 (ld. CIT(A) in short) against the order of assessment passed u/s.143(3) r.w.s. 144C of the Income Tax Act, 1961 (hereinafter referred to as Act) dated 13/03/2014 by the ld. Income Tax Officer 6(3)3, Mumbai (hereinafter referred to as ld. AO).
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