AdvertisementUnicharm India Private Limited Vs DCIT (ITAT Delhi) The Income Tax Appellate Tribunal (ITAT) decided cross appeals filed by the assessee and the Revenue for Assessment Years 2010-11, 2011-12, and 2012-13 arising from assessments completed under Sections 143(3) read with 144C(3) of the Income Tax Act, 1961. The principal dispute concerned transfer pricing adjustments relating to Advertisement, Marketing and Promotion (AMP) expenditure and the determination of the arm’s length price of international transactions. The assessee, a wholly owned subsidiary of Unicharm Corporation, Japan, was e...