https://www.taxtmi.com/caselaws?id=270028 The HC held that the AMP expenses incurred by the Assessee do not constitute an international transaction with its AE, B L, USA, as the Assessee did not receive any subsidy or subvention from the AE. The mere shareholding of 99.9% by B L, USA through B L, South Asia, Inc does not ipso facto establish an international transaction regarding AMP expenses. The Court rejected the Revenue's contention that benefits accruing to the AE alone suffice to infer an international transaction, aligning with precedent in Maruti Suzuki India Ltd. The re-characterization of transactions by the TPO beyond commercial expediency was also found impermissible. Consequently, the Court answered the question in favor of the Assessee and against the Revenue, holding that no international transaction involving AMP expenses existed between the parties. en-us Wed, 23 Dec 2015 00:00:00 +0530 Thu, 24 Jul 2025 16:43:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=270028 The HC held that the AMP expenses incurred by the Assessee do not constitute an international transaction with its AE, B L, USA, as the Assessee did not receive any subsidy or subvention from the AE. The mere shareholding of 99.9% by B L, USA through B L, South Asia, Inc does not ipso facto establish an international transaction regarding AMP expenses. The Court rejected the Revenue's contention that benefits accruing to the AE alone suffice to infer an international transaction, aligning with precedent in Maruti Suzuki India Ltd. The re-characterization of transactions by the TPO beyond commercial expediency was also found impermissible. Consequently, the Court answered the question in favor of the Assessee and against the Revenue, holding that no international transaction involving AMP expenses existed between the parties. Case-Laws Income Tax Wed, 23 Dec 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=270028