AMP expense can’t be disallowed, Merely because Excess amount has been spent on Advertisement

Gillatte India Ltd. Vs ACIT (ITAT Jaipur) The issue under consideration is Whether the TPO was legally justified in holding that Advertisement marketing and Promotion (AMP) expenditure was not an international transaction even though the assessee was performing Development, Enhancement, maintenance, protection and Exploitation (DEMPE) functions for its AE and doing activity of brand building? ITAT states that, the expenses of the associated enterprise (AE) for creating marketing intangibles and promoting the brand name of its AE, it is for the marketing people to look new products which has co...