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AMP expenditure for own business is not an international transaction without an associated-enterprise arrangement, eliminating transfer pricing adjustment.
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Advertisement, marketing and promotion expenditure incurred for an assessee's own business and market penetration does not constitute an international transaction merely because an associated enterprise receives an incidental benefit. An agreement or arrangement with the associated enterprise is required to establish such a transaction. The bright line test is not a recognised method for inferring an international transaction or making a transfer pricing adjustment. Applying earlier coordinate-bench decisions on materially identical facts, the AMP transfer pricing adjustment was deleted and the assessee's appeal was allowed.
Advertisement, marketing and promotion expenditure incurred for an assessee's own business and market penetration does not constitute an international transaction merely because an associated enterprise receives an incidental benefit. An agreement or arrangement with the associated enterprise is required to establish such a transaction. The bright line test is not a recognised method for inferring an international transaction or making a transfer pricing adjustment. Applying earlier coordinate-bench decisions on materially identical facts, the AMP transfer pricing adjustment was deleted and the assessee's appeal was allowed.
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