Held that that in respect of both the protective and substantive addition made on account of advertisement, marketing and promotion expenditure, the Tribunal has observed that the order of the Tribunal in the assessee’s own case for the assessment year 2011-12, deleting the transfer pricing adjustment made on account of advertisement, marketing and promotion expenditure had been upheld by the court. However, the decision in the appeal would abide by the judgment of the Supreme Court in the special leave petitions filed against those decisions. (AY. 2012-13, 2013-14)
PCIT v. Amadeus India Pvt. Ltd. (No. 2) (2023) 452 ITR 206 / 290 Taxman 201 (Delhi)(HC)
S. 92C : Transfer pricing-Arm’s length price-No international transaction between assessee and its associated enterprises-Band promotion-Advertisement, marketing and promotion-Deletion of disallowance is justified. [S. 37(1), 92]