Tribunal held that where there was a Marketing Fund Agreement (MDF) between assessee and AE regarding AMP and shop display activities, scope and value of International Transaction could not have been expanded beyond reimbursement received under MDF agreement to cover entire gamut of AMP expenditure incurred by assessee during year Tribunal also held that TPO could not have determined 30 days as credit period for computing interest on outstanding receivables, without appreciating actual credit terms offered to AEs. (AY. 2012-13)
Samsung India Electronics (P.) Ltd. v. ACIT (2020) 182 ITD 312 (Delhi)(Trib.)
S. 92C : Transfer pricing-Arm’s length price-Reimbursement of expenses-Bright-Line Text (BLT)-Interest-TPO could not have determined 30 days as credit period for computing interest on outstanding receivables, without appreciating actual credit terms offered to AEs.