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Tribunal held that AMP expenses can, in principle, constitute an international transaction but their existence must be established by tangible material rather than by application of the Bright Line Test (BLT). The BLT lacks statutory mandate and cannot be used to compute or convert protective adjustments into substantive TP adjustments. On the facts the assessee's disclosed and adjusted gross margins exceed comparables, so adequacy of compensation for AMP expenses was found and upward transfer pricing adjustments by TPO/DRP were struck down for the years under appeal.
Tribunal held that AMP expenses can, in principle, constitute an international transaction but their existence must be established by tangible material rather than by application of the Bright Line Test (BLT). The BLT lacks statutory mandate and cannot be used to compute or convert protective adjustments into substantive TP adjustments. On the facts the assessee's disclosed and adjusted gross margins exceed comparables, so adequacy of compensation for AMP expenses was found and upward transfer pricing adjustments by TPO/DRP were struck down for the years under appeal.
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