https://www.taxtmi.com/caselaws?id=269330 Whether advertisement, marketing and sales promotion (AMP) expenditure could be characterised as an "international transaction" under s.92B of the Income-tax Act for Chapter X transfer pricing adjustment was decided by applying the HC ruling in Sony Ericsson. The HC held that AMP spend, absent a qualifying international transaction, cannot be treated or categorised as an international transaction; consequently, no transfer pricing adjustment could be made by the TPO/AO in respect of AMP expenditure, and the Revenue's position failed. Whether the ITAT could direct a fresh benchmarking/comparability analysis based on the Special Bench parameters in LG Electronics was answered against the Revenue, holding such direction unsustainable; the assessee succeeded on this issue as well. en-us Fri, 11 Dec 2015 00:00:00 +0530 Tue, 06 Jan 2026 14:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=269330 Whether advertisement, marketing and sales promotion (AMP) expenditure could be characterised as an "international transaction" under s.92B of the Income-tax Act for Chapter X transfer pricing adjustment was decided by applying the HC ruling in Sony Ericsson. The HC held that AMP spend, absent a qualifying international transaction, cannot be treated or categorised as an international transaction; consequently, no transfer pricing adjustment could be made by the TPO/AO in respect of AMP expenditure, and the Revenue's position failed. Whether the ITAT could direct a fresh benchmarking/comparability analysis based on the Special Bench parameters in LG Electronics was answered against the Revenue, holding such direction unsustainable; the assessee succeeded on this issue as well. Case-Laws Income Tax Fri, 11 Dec 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=269330