https://www.taxtmi.com/caselaws?id=257646 HC held that the Transfer Pricing Officer could validly treat Advertising/Marketing & Promotion (AMP) expenses as part of international transactions and that retrospective insertion of s.92CA(2B) cures earlier procedural defects, remitting factual issues to the Tribunal. AMP expenses qualify as international transactions for arm's-length analysis; Chapter X adjustments differ from s.37(1) deductions. Segregation of bundled transactions is permissible where bundling prevents reliable benchmarking, but must address set-off to avoid double taxation. CP method may be used if appropriate; prime lending rate is not a correct mark-up basis. Royalty payments were upheld in favour of the assessee. en-us Mon, 16 Mar 2015 00:00:00 +0530 Fri, 24 Oct 2025 10:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=257646 HC held that the Transfer Pricing Officer could validly treat Advertising/Marketing & Promotion (AMP) expenses as part of international transactions and that retrospective insertion of s.92CA(2B) cures earlier procedural defects, remitting factual issues to the Tribunal. AMP expenses qualify as international transactions for arm's-length analysis; Chapter X adjustments differ from s.37(1) deductions. Segregation of bundled transactions is permissible where bundling prevents reliable benchmarking, but must address set-off to avoid double taxation. CP method may be used if appropriate; prime lending rate is not a correct mark-up basis. Royalty payments were upheld in favour of the assessee. Case-Laws Income Tax Mon, 16 Mar 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=257646