MNCs' India arms get transfer-pricing relief

The Delhi High Court noted while treating advertising, marketing and promotional expenses by an Indian subsidiary of an MNC as international transactions, under section 92B of the I-T Act, "the exercise undertaken should not result in over- or double-taxation"The court said for any "excess" expenditure established, the Indian subsidiary must be compensated by the parent group. "Such compensation might be included or subsumed in low purchase price or by not charging or charging lower royalty. Direct compensation can also be paid," the court