https://www.taxtmi.com/caselaws?id=259433 AMP transfer pricing adjustments cannot be made mechanically on a bright line test; they require a fresh functional and comparability analysis of the actual agreements, conduct, risks, functions and assets, so the matter was remitted for de novo consideration under the jurisdictional High Court ruling. The disallowance of legal and professional expenses also required verification because the allowability could not be decided from the narration of entries alone without examining supporting vouchers and evidence, so that issue too was sent back for fresh decision after hearing the assessee. The disputed additions were therefore not sustained in full. en-us Wed, 22 Apr 2015 00:00:00 +0530 Mon, 11 May 2015 07:50:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=259433 AMP transfer pricing adjustments cannot be made mechanically on a bright line test; they require a fresh functional and comparability analysis of the actual agreements, conduct, risks, functions and assets, so the matter was remitted for de novo consideration under the jurisdictional High Court ruling. The disallowance of legal and professional expenses also required verification because the allowability could not be decided from the narration of entries alone without examining supporting vouchers and evidence, so that issue too was sent back for fresh decision after hearing the assessee. The disputed additions were therefore not sustained in full. Case-Laws Income Tax Wed, 22 Apr 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=259433