https://www.taxtmi.com/caselaws?id=325397 The High Court held that AMP expenses are international transactions and granted jurisdiction to the TPO to determine their arm's length price. It emphasized bundling AMP expenses with other international transactions for distributors and selecting comparables performing similar functions. The bright line test was deemed inappropriate for non-routine AMP expenses. The Tribunal set aside the TPO's order for applying the incorrect test and failing to consider the assessee's AMP functions. The matter was remanded for fresh assessment in line with the High Court's guidelines, excluding selling expenses directly related to sales. en-us Thu, 03 Dec 2015 00:00:00 +0530 Fri, 18 Mar 2016 08:11:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=325397 The High Court held that AMP expenses are international transactions and granted jurisdiction to the TPO to determine their arm's length price. It emphasized bundling AMP expenses with other international transactions for distributors and selecting comparables performing similar functions. The bright line test was deemed inappropriate for non-routine AMP expenses. The Tribunal set aside the TPO's order for applying the incorrect test and failing to consider the assessee's AMP functions. The matter was remanded for fresh assessment in line with the High Court's guidelines, excluding selling expenses directly related to sales. Case-Laws Income Tax Thu, 03 Dec 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=325397