TP adjustment towards brand development services deleted as no contract exists between the parties: ITAT Chennai

Hyundai Motor India Ltd. Vs ACIT (ITAT Chennai) ITAT Chennai held that transfer pricing adjustment towards brand development services unjustified in absence of contract amongst the assessee and its associated enterprises. Accordingly, AO directed to delete addition made towards brand fee adjustment. Facts- The matter involved here is that TPO proposed adjustment on account of expenses incurred by the assessee for brand building allegedly incurred for the benefit of its AE. TPO held an opinion that the assessee was manufacturing car under license from Hyundai Korea who was the owner of brand ...