“advertising marketing and promotion”

Transfer PricingSection 92CSection 92C3 judgments

DCIT, CIRCLE- 25(1), NEW DELHI vs. WRIGLEY INDIA PVT. LTD., NEW DELHI

ITA 1294/DEL/2022[2015-16]Status: DisposedITAT Delhi29 May 2025AY 2015-16

Bench: Shri Vikas Awasthy & Shri Manish Agarwal

Section 250(6)Section 92CSection 92C(3)Section 92D

contract Research and Development ('R&D') service 36,68,618 Adjustment on account of outstanding receivables 12,51,244 Adjustment on account of Advertising Marketing and Promotion ('AMP') expenses 3,49,67,677 Total 3,98,87,539 9. The AO after giving effect to the order ... vide impugned order dated 30.10.2018 allowed part relief to the assessee wherein the TP adjustments made on account of outstanding receivables and advertisement, marketing and promotion expenses (AMP) were deleted and adjustment on account of provisions of contract R&D services were upheld. The assessee is in appeal against

HAIER APPLIANCES INDIA PRIVATE LIMITED,DELHI vs. DCIT, IT & TP DELHI 2(1)(1), NEW DELHI

In the result the appeal of the assessee in ITA No

ITA 417/DEL/2022[2017-148]Status: DisposedITAT Delhi17 Oct 2023AY 2017-148

Bench: Shri N.K. Billaiya & Ms Astha Chandra

For Appellant: Shri Nageshwar Rao, AdvFor Respondent: Shri Rajesh Kumar, CIT-DR

Section 143(3)Section 254Section 92BSection 92F

adjustment is made on protective basis which has no legal existence as per the provisions of the Act. GROUNDS AGAINST CONSIDERING ADVERTISEMENT, MARKETING AND PROMOTION ("AMP") FUNCTION AS AN INTERNATIONAL TRANSACTION 7. The TPO /AO erred on facts and in law by assuming jurisdiction in respect of the AMP expenditure ... Resolution Panel-1, New Delhi. During the DRP proceedings, the assessee had objected to the Determination of ALP by the TPO regarding AMP (Advertising Marketing and Promotional) expense and Adjustment on account of trading segment [Substantive Adjustment (Intensity) & Protective Adjustment (Brightline Test)]. 3. The TPO in its order vide

DY.CIT 7(1) (1) , MUMBAI vs. M/S. MATTEL TOYS (INDIA) PVT. LTD, MUMBAI

In the result, the appeal of the Revenue is dismissed, whereas,

ITA 2304/MUM/2021[2012-13]Status: DisposedITAT Mumbai29 Dec 2022AY 2012-13

Bench: Shri Vikas Awasthy () & Shri Om Prakash Kant () Assessment Year: 2012-13 Dy. Cit, Circle-7(1)(1), M/S Mattel Toys (India) Pvt. Ltd., Room No. 126, 1St Floor, Phoenix House, B-Wing, 4Th Floor, Vs. Aayakar Bhavan, M.K. Road, 462, Senapati Bapat Marg, Lower Mumbai-400020. Parel, Mumbai-400013. Pan No. Aaccm 2563 P Appellant Respondent

For Respondent: Assessee by Mr. Ketan Ved, AR

contention that expenditure on in rejecting the Respondent's contention that expenditure on in rejecting the Respondent's contention that expenditure on Advertising, Marketing and Promotion ("AMP") Advertising, Marketing and Promotion ("AMP") Advertising, Marketing and Promotion ("AMP") is not an international transaction. international transaction. 1.2 The Respondent submits that expenditure ... made addition for transfer 144C(3) of the Act, the Assessing Officer made addition for transfer pricing adjustment of a pricing adjustment of advertising marketing and promotion (AMP) dvertising marketing and promotion (AMP) expenses of ₹4,80,31,291/ 4,80,31,291/- along with disallowance of depreciation along with