Outward Freight not to be considered for TP adjustment as same doesn’t operate from transaction perspective

Michelin India Pvt. Ltd. Vs DCIT (ITAT Delhi) Conclusion: Outward freight in India except the freight for import of material distributed be not considered for adjustment as it is not operating from transaction perspective. Held:  Assessee-company was into import and resale (or trading) of tyres for passenger cars, trucks and buses under the brand name ‘Michelin’. During the year under assessment, the taxpayer entered into International Transaction with its Associate Enterprises (AE). TPO noticed that the taxpayer had incurred huge Advertisement, Marketing and Promotional (AMP) expenses to...