https://www.taxtmi.com/caselaws?id=260205 Transfer pricing adjustment for advertising, marketing and promotion expenses was held unsustainable on the existing record because the AMP functions of the assessee and the comparables had not been properly examined or compared. The Tribunal noted that the bright line test could not be applied and that benchmarking must consider the actual AMP functions performed, with different treatment for manufacturers and distributors. As the material on record was insufficient to test these principles, the transfer pricing analysis was set aside and the matter remitted to the AO/TPO for fresh adjudication in accordance with law and the applicable Delhi High Court principles. en-us Tue, 02 Jun 2015 00:00:00 +0530 Thu, 04 Jun 2015 11:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=260205 Transfer pricing adjustment for advertising, marketing and promotion expenses was held unsustainable on the existing record because the AMP functions of the assessee and the comparables had not been properly examined or compared. The Tribunal noted that the bright line test could not be applied and that benchmarking must consider the actual AMP functions performed, with different treatment for manufacturers and distributors. As the material on record was insufficient to test these principles, the transfer pricing analysis was set aside and the matter remitted to the AO/TPO for fresh adjudication in accordance with law and the applicable Delhi High Court principles. Case-Laws Income Tax Tue, 02 Jun 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=260205