Case Law Details
Case Name : M/s Essilor India Pvt. Ltd. Vs DCIT (ITAT Bangalore)
Related Assessment Year : 2009-10 & 2010-11
Courts :
All ITAT ITAT Bangalore
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Brief of the Case
ITAT Bangalore held in the case of M/s Essilor India Pvt. Ltd. vs. DCIT that no TP adjustment can be made by deducing from the difference between AMP expenditure incurred by assessee and AMP expenditure of comparable entity, if there is no explicit arrangement between the assessee and its foreign AE for incurring such expenditure. The fact that the benefit of such AMP expenditure would also benefit to its foreign AE is not sufficient to infer existence of international transaction. The
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