ITAT Mumbai Deletes Rs. 184.75 Cr AMP TP Adjustment in L’Oréal India Case

L’Oreal India Private Limited Vs DCIT (ITAT Mumbai) AO/TPO had alleged that AMP expenses incurred by the Assessee constituted an international transaction in the nature of brand promotion services for its AE, warranting adjustment with a mark-up. The DRP upheld the adjustment. Before the Tribunal, Assessee argued that AMP expenses were incurred wholly & exclusively for its own business in India, with no agreement or arrangement with AE for brand promotion. Reliance was placed on Tribunal’s consistent decisions in Assessee’s own cases from AY 2008-09 to AY 2020-21, where similar adjus...