Sponsored
    Follow Us:

Case Law Details

Case Name : HP India Sales Private Limited Vs JCIT (ITAT Bangalore)
Appeal Number : IT(TP)A No. 524/Bang/2017
Date of Judgement/Order : 18/08/2022
Related Assessment Year : 2012-2013
Become a Premium member to Download. If you are already a Premium member, Login here to access.
Sponsored

HP India Sales Private Limited Vs JCIT (ITAT Bangalore)

Held that TP adjustment, relating to Advertisement, Marketing and Promotion expenditure incurred by the assessee, merely on the basis of presumption that expenses are incurred at the instance or on behalf of the AE is unsustainable

Facts-

During the course of assessment proceedings, it was noticed that international transaction with the AEs exceeded the prescribed limit, therefore, the matter was referred to the Transfer Pricing Officer (TPO) to determine the Arm’s Length Price (ALP) of the said transactions.

The TPO u/s 92CA vide order dated 28.01.2016 proposed TP adjustment of Rs.29,03,35,855. Pursuant to the TPO’s order, draft assessment order was passed on 28.03.2016 u/s 143(3) r.w.s. 144C(1) of the I.T.Act incorporating the above said TP adjustment proposed by the TPO. AO also made certain additions / disallowances on the corporate tax front.

Please become a Premium member. If you are already a Premium member, login here to access the full content.

Sponsored

Join Taxguru’s Network for Latest updates on Income Tax, GST, Company Law, Corporate Laws and other related subjects.

Leave a Comment

Your email address will not be published. Required fields are marked *

Sponsored
Sponsored
Search Post by Date
July 2024
M T W T F S S
1234567
891011121314
15161718192021
22232425262728
293031