“advertising marketing and promotion”

Transfer PricingSection 92CSection 92C3 judgments

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

In the result, the appeal of the Assesse in ITA No

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

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

vide impugned order dated 30.10.2018 allowed part relief to the\nassessee wherein the TP adjustments made on account of outstanding\nreceivables and advertisement, marketing and promotion expenses (AMP) were\ndeleted and adjustment on account of provisions of contract R&D services were\nupheld. The assessee is in appeal against ... company, is engaged in manufacturing and selling confectionery products. The case involves transfer pricing adjustments related to contract R&D services, Advertising Marketing and Promotion (AMP) expenses, and interest on external commercial borrowings (ECB). The assessee filed appeals against additions made by the TPO, while the revenue filed appeals 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