Tribunal held that TPO had combined royalty payments along with AMP expenses while making Transfer pricing adjustments by adopting Residual Profit Split Method. AMP expenses required to be shown separately matter remanded for fresh examination. (AY. 2015-16)
Kontoor Brands India (P.) Ltd. v. DCIT (2021) 188 ITD 503 (Bang.)(Trib.)
S. 92C : Transfer pricing-Arm’s length price-Profit Split Method Royalty and AMP expenses-Required to be shown separately-Matter remanded.