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In the PepsiCo case @(2023] 30 ITR (Trib)-OL 1 (ITAT[Del]) the subject matter of appeal was essentially covered by the previous orders of the Tribunal in favour of assessee based on which the AO/TPO was asked to delete the transfer pricing adjustment made on account of AMP expenses.


However there is one aspect that is worth noticing in this case and that is as many as 31 grounds of appeal are made out on the single effective subject of AMP expenses TP adjustment out of which as many as 29 grounds are mere argumentative in nature. 


Now by incorporating your arguments and contentions upfront as part of grounds of appeals the court or tribunal may though write them as mere argumentative or descriptive or problematic the appellant however may end up providing advance ammunition to the other side and that in all probability may adversely affect at the time of actual hearing of the matter. 

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