Allowing the appeal of the assessee the Tribunal held that there was no evidence to show that by incurring expenses the assesee had enhanced brand value and created intangibles in favour of its associated enterprise. Adjustment made in respect of advertisement marketing and sales promotion expenses were deleted. (AY. 2011-12)
Xerox India Ltd. v. Dy. CIT (2021) 87 ITR 209 (Delhi)(Trib.)
S. 92B : Transfer pricing-Arm’s length price-Advertisement, marketing and sales promotion expenses-Incidental benefit to foreign associated enterprise not to be concluded as brand building exercise. [S.92C]