Accepting the parameters of the “bright line test” and if the said para meters and tests are applied to Indian companies with reputed brands and substantial AMP expenses would lead to difficulty and unforeseen tax implications and complications. Tata, Hero, Mahindra, TVS, Baja], Godrej, Videocon group and several others are both manufacturers and owners of intangible property in the form of brand names. They incur substantial AMP expenditure. If we apply the “bright line test” with reference to indicators mentioned in paragraph https://1investing.in/ 17.4 as well as the ratio expounded by the majority judgment in L. Ltd.’s case in paragraph 17.6 to bifurcate and segregate the AMP expenses towards brand building and creation, the results would be startling and unacceptable. The same is the situation in case we apply the parameters and the “bright line test” in terms of paragraph 17.4 or as per the contention of the Revenue, i.e., AMP expenses incurred by a distributor who does not have any right in the intangible brand value and the product being marketed by him.
In some cases expenditure is incurred to generate future economic benefits but it may not insult in creation of an intangible asset in the form of goodwill or brand, which meets the recognition criteria under AS26. Internally generated goodwill or brand is not treated as an asset in AS-26 because it is not an identifiable resource controlled by an enterprise, which can be reliably measured at cost. Its value can change due to a range of factors. Such uncertain and unpredictable differences, which would occur in future, are indeterminate. In subsequent paragraphs, AS-26 records that expenditure on materials and services used or consumed, salary, wages and employment related costs, overheads, etc., contribute in generating internal intangible asset. Thus, it is possible to compute good- will or brand equity/value at a point of time but its future valuation would be perilous and an iffy exercise.
Without prejudice, the TPO/DRP/AO erred in adopting the “Other Method”, without justifying the non-applicability of all the other prescribed methods under the Rules, for the purposes of computing the ALP of the alleged “international transaction” of AMP Expenses incurred by the Appellant. Without prejudice, the TPO/DRP/AO erred in concluding that AMP expenses incurred by the Appellant resulted in the enhanced brand value of the brands owned by the AE. Without prejudice, the TPO/DRP/AO grossly erred in concluding that carrying out of AMP expenses was an “international transaction” for the purposes of section 92B of the Act based on assumptions, surmises and conjectures.
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Click on Order Now button and select the Brisk report to get the latest 5-year financials of AMPERE INTERNATIONAL TRADING AND CONTRACTING PRIVATE LIMITED. Select InstaDetailed report for accessing the latest 3-year financial data. Click here to view the product comparison. The company is registered with email address The Media coordination team of GEEPL is very friendly and can be reached by email all times for any latest news and Information. International transactions cannot be found to exist after applying the BLT to decipher and compute value of international transaction.
USA Import data reveals the international trade transaction for USA import and overseas suppliers.
The profit thus apportioned to the assessee is to be taken into account 16 to arrive at an arm’s length price in relation to the international transaction. Revenue cannot resort to a quantify the adjustment by determining the AMP expenses spent by the assessee after applying BLT to hold it to be excessive and thereby evidencing the existence of the international transaction involving the AE. The solitary issue to be adjudicated in this appeal pertains to transfer pricing adjustment on account of AMP expenses. Without prejudice, the TPO/DRP/AO grossly erred on facts and in law in concluding that the AE, being the legal owner of the brands, should have compensated the Appellant for AMP Expenses incurred by it towards such brands, as the AE derived brand enhancement benefits because of such expenses.
- It’s a company limited by shares having an authorized capital of Rs 1.00 lakh and a paid-up capital of Rs 1.00 lakh as per MCA.
- The same is the situation in case we apply the parameters and the “bright line test” in terms of paragraph 17.4 or as per the contention of the Revenue, i.e., AMP expenses incurred by a distributor who does not have any right in the intangible brand value and the product being marketed by him.
- The solitary issue to be adjudicated in this appeal pertains to transfer pricing adjustment on account of AMP expenses.
- Accounting Standard 26 exemplifies distinction between expenditure HJ7 incurred to develop or acquire an intangible asset and internally generated goodwill.
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The GM International Socket – 2 Module – Pack of 10 ensures safe and hassle free operation. It features a top grade polycarbonate construction and a white glossy finish. GM is one of the most reputed brands in India. It offers innovative and advanced products that deliver an efficient performance.
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International transaction cannot be identified or held to be existing simply because excess AMP expenditure has been incurred by the Indian entity. 3.2 Ground Nos. 2 to 2.21 relate to the adjustment on account of AMP expenses. Without prejudice, the TPO/DRP/AO erred in arbitrarily construing the alleged “international transaction” of incurring AMP Expenses as a “service”, without bringing any evidence on record to establish such “arrangement” between the Appellant and its AE.
The estimate would represent the set off of economic conditions that will exist over the useful life of the intangible asset. At the initial stage, intangible asset should be measured at cost. The above proposition would not apply to internally generated goodwill or brand. Paragraph 35 specifically elucidates that internally generated goodwill should not be recognised as an asset.
The supplier company is located in hounslow, Middlesex and is one of the leading sellers of listed products. The company got registered under GST on December 25, 2019 and was allotted 32AASCA9382N1ZV as the GST Number. The status of this GSTIN is Active. This company is a Regular taxpayer . Purchase reports or subscription to get access to information on legal cases of company in the District Courts, High Courts and Supreme Court of India. Big thanks to showing your interest in SEAIR Exim Solutions.
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The brand is a market leader when it comes to switches and home electrical accessories. GM’s products are known for their exclusive designs and superior quality. Click on Order Now button and select the Brisk report or InstaLegal report to get the information of the legal case file and filed against AMPERE INTERNATIONAL TRADING AND CONTRACTING PRIVATE LIMITED. Click here to view the product comparison. “6.40 The legal owner will be considered to be the owner of the intangible for transfer pricing purposes. There is no provision either in the Act or in the Rules to justify the application of BLT for computing the Arm’s Length Price and there is nothing in the Act which indicate how in the absence of BLT one can 5 discern the existence of an international transaction as far as AMP expenditure is concerned. Without prejudice, the TPO/AO/DRP erred in not carrying out a separate benchmarking analysis, based on domestic comparables, for the purposes of applying BLT for computing the ALP of the alleged “international transaction” of AMP Expenses, incurred by the Appellant.
AMP International Metals LTD. is listed in Trade India’s list of verified sellers offering supreme quality of etc. Buy in bulk from us for the best quality products and service. Is popularly known as AMPERE INTERNATIONAL TRADING AND CONTRACTING PRIVATE LIMITED. It is a Private Limited Company with its office registered in Kerala . The company carries out its major operations from Kerala.
Its registered office is in Thiruvananthapuram, Kerala, india. We don’t offer any assistance over buying or selling any products. Seair is proud to have a loyal customer base from big brands. Company Designation Appointment Date Cessation Date Login to view this information.
Without prejudice, the TPO/DRP/AO erred in comparing the ratio of AMP/ Sales of the assessee with that of the Pepsi Group globally, while applying BLT for the purposes of computing the ALP of the alleged “international transaction” of AMP Expenses, incurred by the Appellant. Without prejudice, the TPO/DRP/AO erred in applying BLT in complete ignorance of the precedents set by the Hon’ble jurisdictional High Court against the application of BLT for the purposes of computing the ALP of the alleged “international transaction” of AMP Expenses, incurred by the Appellant. Without prejudice, the TPO/DRP/AO erred in applying the Bright Line Method (“BLT”), under the guise of “Other Method”, for the purposes of computing the ALP of the alleged “international transaction” of AMP Expenses, incurred by the Appellant.
This would be unrealistic and impracticable, if not delusive and misleading (aforesaid reputed Indian companies, it is patent, are not to be treated as comparables with the assessee, i.e., the tested parties in these appeals, for the latter are not the legal owners of the brand name/trade mark). Accounting Standard 26 exemplifies distinction Introduction to Level II Quotes between expenditure HJ7 incurred to develop or acquire an intangible asset and internally generated goodwill. An intangible asset should be recognised as an asset, if and only if, it is probable that future economic benefits attributable to the said asset will flow to the enterprise and the cost of the asset can be measured reliably.
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Without prejudice, the TPO/DRP/AO erred in not allowing the benefit of imputed “royalty” taxed in the hands of Pepsi Co. Inc., USA, while computing adjustment on account of AMP Expenses. Without prejudice, the TPO/DRP/AO failed to appreciate that AMP Expenses incurred by the Appellant formed a part of the excisable value of goods and hence, partook the character of “manufacturing expenses”, which could not have been re-characterized. CAs, experts and businesses can get GST ready with ClearTax GST software & certification course. Our GST Software helps CAs, tax experts & business to manage returns & invoices in an easy manner.
The Company’s status is Active. It’s a company limited by shares having an authorized capital of Rs 1.00 lakh and a paid-up capital of Rs 1.00 lakh as per MCA. Ampere International Trading And Contracting Private Limited is a 3 years 6 days old Private Company incorporated on 15 Nov 2019.