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Delhi High Court holds that advertising, marketing and promotion (AMP) activity is not an international transaction

Global Tax Update:February 2016/India

Tax authorities had made transfer pricing adjustment alleging that excess advertising, marketing and promotion (AMP) expenditure incurred by the Indian company vis-à-vis the comparable companies had created marketing intangible for its associated enterprise (AE), S company, for which it should have received arm’s length compensation from company S. (Global Tax Update:February 2016/India)

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1. Delhi High Court holds that advertising, marketing and promotion (AMP) activity is not an international transaction

The High Court held that the alleged excess AMP expenditure incurred by the Indian Company cannot be regarded as an international transaction in the absence of any agreement or arrangement between the company and its AE.

2. Electronic filing of first appeal before Commissioner of Income-tax (Appeals) (CIT (A))

As another significant step towards digitization and simplification of tax procedures in India, electronic filing of appeal before Commissioner of Income-tax (CIT (A)) is being made mandatory for taxpayers who are required to file the return of income electronically.

 

>> Click for Japanese [デリー高等裁判所判決:広告、マーケティングおよび販売プロモーションは国際取引ではない、ほか]

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