TPO cannot retain comparables in a summary fashion with no cogent reason

PCIT Vs Amway India Enterprises (Delhi High Court)

In the present appeal, the learned counsel for the Appellant states that the ITAT erred in confirming the order of the CIT(A) and failed to appreciate the fact that the royalty payment is excessive and not at arm’s length on consideration of Advertisement, Marketing and Promotion (‘AMP’) expenses incurred by the assessee for the benefit of the AE’s trademark and brand. He states that the ITAT erred in not appreciating that the foundation of the adjustment with respec

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