M/S.JOY ALUKKAS INDIA P. LTD,TRICHUR vs. THE ACIT, ERNAKULAM
In the result, the appeal filed by the Assessee stands partly allowed for statistical purposes
ITA 119/COCH/2016[2011-12]Status: DisposedITAT Cochin08 Sept 2025AY 2011-12
Bench: Shri Inturi Rama Rao, Am& Shri Rahul Chaudharyit (Tp) A No. 119/Coch/2016 (Assessment Year: 2011-12) & It (Tp) A Nos. 38 & 643/Coch/2017 (Assessment Years :2012-13 & 2013-14)
For Appellant: Smt. Parvathy Ammal, CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 143(3)Section 36(1)(iii)Section 36(1)(viii)Section 92C
section 92B. The DRP failed to appreciate that the Transfer Pricing Officer had on its own benchmarked the advertisement expenses incurred in India although was not referred to the TPO. The DRP failed to appreciate that advertisement expenses incurred in India by themselves did not constitute an international transaction in the absence of any specific reference being made in that
