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AMP Issue Under Transfer Pricing – A Long Battle

June 29, 2020[2020] 117 378 (Article)
However, from transfer pricing perspective where AMP expenditure is incurred by associated enterprise of a foreign company, such AMP expenditure has been a matter of long time litigation as Transfer Pricing Officer (TPO) considers AMP as an international transaction by invoking Section 92CA(2A) of the Income Tax Act,1961 and make adjustment on account of AMP expenditure in the hands of AE.
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