https://www.taxtmi.com/caselaws?id=269884 AMP expenses cannot be treated as an international transaction under transfer pricing law unless the Revenue first produces tangible material showing an actual understanding, arrangement, or action in concert with the foreign associated enterprise. Mere group relationship or incidental benefit to the foreign brand is insufficient, because Chapter X applies to an existing transaction and cannot be used to invent one by comparing AMP spend with comparables. On that basis, the Delhi HC stated that the AMP expenditure did not constitute an international transaction and that the related adjustment under the Income-tax Act could not be sustained, with the transfer pricing addition on AMP expenses set aside. en-us Tue, 22 Dec 2015 00:00:00 +0530 Fri, 24 Oct 2025 10:17:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=269884 AMP expenses cannot be treated as an international transaction under transfer pricing law unless the Revenue first produces tangible material showing an actual understanding, arrangement, or action in concert with the foreign associated enterprise. Mere group relationship or incidental benefit to the foreign brand is insufficient, because Chapter X applies to an existing transaction and cannot be used to invent one by comparing AMP spend with comparables. On that basis, the Delhi HC stated that the AMP expenditure did not constitute an international transaction and that the related adjustment under the Income-tax Act could not be sustained, with the transfer pricing addition on AMP expenses set aside. Case-Laws Income Tax Tue, 22 Dec 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=269884