Held that expenses on advertisement and publicity, business promotion and participation in trade events at the request of the overseas AE which are reimbursed, they should be treated as pass through cost and all other items of expenses are to be considered as part of the cost base of the assessee and should be marked-up. (AY. 2004-05)
ACIT v. BBC World (India) (P) Ltd. (2023) 156 taxmann.com 386 /37 NYPTTJ 1515 / (2024) 229 TTJ 601 / 237 DTR 201 (Delhi)(Trib)
S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Reimbursement of third party cost for marketing and research-Expenses relating to advertisement were on buying of advertisement space in the newspapers-Pass through entities-Other than these three items, all other items should be considered as part of the cost base o and should be marked-up-Order of CIT(A) is affirmed.
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