https://www.taxtmi.com/caselaws?id=270029 The dominant issue was whether incurrence of advertisement, marketing and promotion (AMP) expenditure constituted an "international transaction" with the assessee's foreign AE for TP adjustment. The HC held Sony Ericsson inapplicable because, unlike those cases, the alleged transaction here was inferred only by applying the disapproved Bright Line Test (BLT), and the Revenue failed to independently discharge its initial onus to establish such a transaction; accordingly, the issue was decided for the assessee. On merits, the HC accepted that the assessee predominantly carried on manufacturing, devised and executed its own marketing strategy, bore entrepreneurial risks, and was not a contract manufacturer; absent evidence that AMP was incurred at the AE's instance or required reimbursement, no benchmarking of AMP was warranted. The appeal was allowed for the assessee and against the Revenue. en-us Wed, 23 Dec 2015 00:00:00 +0530 Tue, 06 Jan 2026 15:03:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=270029 The dominant issue was whether incurrence of advertisement, marketing and promotion (AMP) expenditure constituted an "international transaction" with the assessee's foreign AE for TP adjustment. The HC held Sony Ericsson inapplicable because, unlike those cases, the alleged transaction here was inferred only by applying the disapproved Bright Line Test (BLT), and the Revenue failed to independently discharge its initial onus to establish such a transaction; accordingly, the issue was decided for the assessee. On merits, the HC accepted that the assessee predominantly carried on manufacturing, devised and executed its own marketing strategy, bore entrepreneurial risks, and was not a contract manufacturer; absent evidence that AMP was incurred at the AE's instance or required reimbursement, no benchmarking of AMP was warranted. The appeal was allowed for the assessee and against the Revenue. Case-Laws Income Tax Wed, 23 Dec 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=270029