AMP Expenses Not an International Transaction for transfer pricing: Delhi HC

PCIT Vs Wrigley India Pvt. Ltd. (Delhi High Court) Introduction: In a recent decision related to the Assessment Year 2010-11, the Delhi High Court addressed the contentious issue of whether Wrigley India Pvt. Ltd., a wholly-owned subsidiary of its Associated Enterprise (AE), should be compensated for Advertising, Marketing, and Promotion (AMP) expenses incurred on behalf of its AE. The appellant, seeking to challenge the order, claimed that the Transfer Pricing Officer (TPO) had made an adjustment on the Arm’s Length Price for what was perceived as an international transaction concerning...