Indian Income Tax Authorities have invariably been “marking up” the advertising, marketing and promotion (AMP) expenses incurred by the Indian units to promote brands legally owned by the foreign parent, leading to uncertainty in the area of transfer pricing. The attached article talks about the ruling of Delhi Bench of ITAT against Casio India stating that the excessive advertising, marketing and promotion (AMP) expenses should be recovered from Casio Japan along with arm’s length mark-up.

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