https://www.taxtmi.com/caselaws?id=261120 The Delhi High Court rejected the bright line test for determining adjustments for Advertisement, Marketing, and Promotion (AMP) expenses in international transactions. The court directed the Transfer Pricing Officer (TPO) to benchmark AMP functions without the bright line test, exclude direct selling and distribution expenses from AMP expenses, and consider the entity-level Profit Level Indicator (PLI) that includes AMP expenses. The court set aside the assessment order and remanded the matter to the TPO for fresh consideration, partially allowing the assessee's appeal for statistical purposes. en-us Fri, 19 Jun 2015 00:00:00 +0530 Fri, 03 Jul 2015 07:46:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=261120 The Delhi High Court rejected the bright line test for determining adjustments for Advertisement, Marketing, and Promotion (AMP) expenses in international transactions. The court directed the Transfer Pricing Officer (TPO) to benchmark AMP functions without the bright line test, exclude direct selling and distribution expenses from AMP expenses, and consider the entity-level Profit Level Indicator (PLI) that includes AMP expenses. The court set aside the assessment order and remanded the matter to the TPO for fresh consideration, partially allowing the assessee's appeal for statistical purposes. Case-Laws Income Tax Fri, 19 Jun 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=261120