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ThynkTax /Tax Reference /Case Laws /Sony India - AMP first principles

Sony India - AMP first principles

High Court·2017·ITR
Facts

Sony India marketing spend on parent's brand.

Issue

AMP as international transaction.

Held

AMP is not deemed international transaction without proven agreement or arrangement with the foreign AE.

Ratio

Transfer pricing requires evidence of actual international transaction; cannot be inferred from comparable analysis.

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