https://www.taxtmi.com/caselaws?id=234633 Transfer pricing adjustments addressed allocation of AMP expenditures and valuation of brand-building activities, with excess AMP spends attributable to services rendered for a non-residents marketing intangible treated as an international transaction and collectible as consideration; only excess AMP over comparable averages was added. The Bright Line test was held to fit within prescribed ALP methodology though procedural steps in Rule 10B(1)(c) required adherence. Selling expenses unconnected to logo building were excluded from AMP. Comparables must be independent and adjusted; prior sets were inadequate. Product design costs apportioned 50:50 between parties. Provisions without write-offs were disallowed; penalties for statutory tax breaches were disallowed as business deductions; government subsidy classified as capital receipt. en-us Tue, 04 Jun 2013 00:00:00 +0530 Sat, 24 Jan 2026 09:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=234633 Transfer pricing adjustments addressed allocation of AMP expenditures and valuation of brand-building activities, with excess AMP spends attributable to services rendered for a non-residents marketing intangible treated as an international transaction and collectible as consideration; only excess AMP over comparable averages was added. The Bright Line test was held to fit within prescribed ALP methodology though procedural steps in Rule 10B(1)(c) required adherence. Selling expenses unconnected to logo building were excluded from AMP. Comparables must be independent and adjusted; prior sets were inadequate. Product design costs apportioned 50:50 between parties. Provisions without write-offs were disallowed; penalties for statutory tax breaches were disallowed as business deductions; government subsidy classified as capital receipt. Case-Laws Income Tax Tue, 04 Jun 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=234633