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Transfer Pricing adjustment of advertisement, marketing and promotion deleted as not an international transaction
Case Law Details
- Case Name
- Philips India Limited Vs DCIT (ITAT Kolkata)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2012-22
- Courts
- All ITAT, ITAT Kolkata
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Philips India Limited Vs DCIT (ITAT Kolkata)
ITAT Kolkata held that the advertisement, marketing and promotion expenses [AMP Expense] not an international transaction and accordingly, the TP adjustment made by Transfer Pricing Officer/ AO is to be deleted. Accordingly, appeal allowed to that extent.
Facts- The present appeal has been preferred by the assessee. The transfer priding adjustment of ₹54,41,41,000/- on account of provision of software development services is mainly contested. The issue raised in respect of transfer pricing adjustment of ₹94,41,22,563/- towards alleged advertis...






