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Indian Court Rules Transfer Pricing Adjustment not Allowed without a Demonstrated International Transaction

|Approved Changes|India
India

On 11 December 2015, the High Court of Delhi issued its decision concerning a transfer pricing adjustment related to excessive advertising, marketing, and sales promotion expenses (AMP). The case involved Maruti-Suzuki India Ltd. and its affiliated enterprise Suzuki Motor Corp. headquartered in Japan.

In the year concerned, Maruti-Suzuki India was considered to have incurred excessive AMP expenses in India on behalf of Suzuki Motor Corp. based on the assumed existence of an international tra…

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