Marketing support and subcontracted client contracts: no agency permanent establishment under Article 5 DTAA; arm's-length pricing bars profit attribu...
Dominant issue: whether the Bright Line Test (BLT) is an appropriate benchmarking method for AMP expense allocation. The tribunal held that BLT is not a sustainable basis for transfer-pricing adjustment, relying on the precedent that rejected BLT for AMP allocations and emphasizing legal insufficiency of the AO/TPO's application of BLT; consequence: the adjustment/addition made to AMP expenses is deleted and the appeal is allowed. - ITAT
Dominant issue: whether the Bright Line Test (BLT) is an appropriate benchmarking method for AMP expense allocation. The tribunal held that BLT is not a sustainable basis for transfer-pricing adjustment, relying on the precedent that rejected BLT for AMP allocations and emphasizing legal insufficiency of the AO/TPO's application of BLT; consequence: the adjustment/addition made to AMP expenses is deleted and the appeal is allowed. - ITAT
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