Dismissing the appeal, the Court held that the Tribunal was justified in directing the exclusion of routine sales and distribution expenses and rejecting the transfer pricing adjustment of advertising, marketing and promotion using the bright line method. (AY. 2011-12)
PCIT v. Sharp Business Systems (India) Pvt. Ltd. (2025) 472 ITR 582 (Delhi) (HC)
S. 92C : Transfer pricing-Advertising, marketing and promotion expenses are not international transaction-Tribunal directing exclusion of routine sales and distribution expenses-Not erroneous.[S. 260A]
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