The Indian Income Tax Appellate Tribunal (ITAT) issued its decision on 26 February 2013 in the case of ACIT v. Funskool (India) Ltd. (ITA No. 110/Mds/2008) that the Taxpayer, who used the comparable uncontrolled price method, was correct to adjust the arm's length price (ALP) for expenses incurred in connection with advertisement, marketing, sales and administrative departments. The ITAT noted that the Taxpayer had not incurred advertisement and marketing expenses for sales (97% of sales) made to the associated enterprise in the United States. Further, the ITAT rejected the Taxpayer's contention on the second issue of adjusting to ALP by...