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| The Tax Publishers2019 TaxPub(DT) 2754 (Del-Trib) INCOME TAX ACT, 1961
Section 92C
Bright line test could not be used for making adjustment of excessive, advertisement and marketing and promotion expenditure.
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Transfer pricing - Determination of ALP - AMP expenses - Application of bright line test
TPO suggested protective adjustment in respect of international transaction of advertisement, marketing promotion expenditure by applying bright line test.Held: Bright line test could not be used for making adjustment of excessive advertisement ,marketing and promotion expenditure.
Followed:Sony Ericsson Mobile Communications India (P.) Ltd. v. CIT (2015) 374 ITR 118 (Del) : 2015 TaxPub(DT) 1653 (Del-HC).
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2013-14
INCOME TAX ACT, 1961
Section 92C
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