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The ITAT deleted the Transfer Pricing adjustment relating to AMP expenses incurred by the appellant as an international transaction under section 92B. The tribunal relied on its coordinate bench's precedent, holding that since the appellant demonstrated arm's length remuneration from distribution services, including subvention income exceeding the adjustment amount, no further addition was justified. The TPO's reliance on the Bright Line Test was rejected as lacking statutory basis. Consequently, the impugned Transfer Pricing adjustment was set aside, and the appellant's appeal on this ground was allowed.
The ITAT deleted the Transfer Pricing adjustment relating to AMP expenses incurred by the appellant as an international transaction under section 92B. The tribunal relied on its coordinate bench's precedent, holding that since the appellant demonstrated arm's length remuneration from distribution services, including subvention income exceeding the adjustment amount, no further addition was justified. The TPO's reliance on the Bright Line Test was rejected as lacking statutory basis. Consequently, the impugned Transfer Pricing adjustment was set aside, and the appellant's appeal on this ground was allowed.
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