Sony India faced transfer pricing adjustments across multiple assessment years covering AMP expenses, royalty payments, and advisory services. India's Income Tax Appellate Tribunal held that neither the Bright Line Test nor intensity adjustments are permissible benchmarking methods under the Income Tax Act, deleting both AMP and royalty adjustments. The Tribunal also directed revisions to the comparables set for advisory services, deciding the case mostly in Sony's favour ... Read more

Hyundai Motor India faced transfer pricing adjustments on advertising, marketing and promotional expenses, which tax authorities treated as an international transaction benefiting its Korean parent. The Income Tax Appellate Tribunal deleted all adjustments for the years under appeal, finding no written agreement obligating Hyundai Motor India to promote the foreign brand. The expenses were incurred solely for the Indian company's own business and could not constitute an international transaction ... Read more