Absence of Express Agreement for Brand Promotion Excludes AMP Expenditure as International Transaction: ITAT deletes Addition on Kellogg India

No express agreement - agreement - No express agreement between parties for incurring expenditure - expenditure -ITAT - taxscan

The Mumbai bench of the Income Tax Appellate Tribunal (ITAT) held that the transactions in question would not constitute international transaction relating to AMP expenditure. The Assessee Company, Kellogg India, claimed to be a wholly owned subsidiary of Kellogg USA and having principal activity of manufacturing and selling of breakfast cereal products in India and…

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