https://www.taxtmi.com/caselaws?id=245355 The court upheld the application of the Bright Line Test for determining the Arm's Length Price (ALP) of Advertising, Marketing, and Promotion (AMP) expenses in international transactions. The Assessing Officer was directed to consider specific factors before deciding on the transfer pricing adjustment related to AMP expenses. The court rejected the argument that there was no 'transaction' concerning AMP expenses and remitted the matter for a fresh determination of the transfer pricing adjustment. The court also directed the exclusion of 'Incentive' amounts from total AMP expenses, considering them as selling expenses to be deducted for determining the ALP. The appeal was partly allowed based on these conclusions. en-us Thu, 06 Mar 2014 00:00:00 +0530 Wed, 15 Feb 2017 10:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=245355 The court upheld the application of the Bright Line Test for determining the Arm's Length Price (ALP) of Advertising, Marketing, and Promotion (AMP) expenses in international transactions. The Assessing Officer was directed to consider specific factors before deciding on the transfer pricing adjustment related to AMP expenses. The court rejected the argument that there was no 'transaction' concerning AMP expenses and remitted the matter for a fresh determination of the transfer pricing adjustment. The court also directed the exclusion of 'Incentive' amounts from total AMP expenses, considering them as selling expenses to be deducted for determining the ALP. The appeal was partly allowed based on these conclusions. Case-Laws Income Tax Thu, 06 Mar 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=245355