https://www.taxtmi.com/caselaws?id=195053 The High Court upheld the Transfer Pricing Officer's jurisdiction to make adjustments on Advertising, Marketing, and Promotion (AMP) expenses, categorizing them as international transactions under Section 92B of the Income Tax Act, 1961. The court emphasized the need for a detailed functional and comparability analysis, rejecting the 'bright line test' and directing a practical approach for determining the Arms Length Price (ALP). The case was remitted back to the Assessing Officer/Transfer Pricing Officer for fresh determination following the High Court's guidance. en-us Wed, 28 Oct 2015 00:00:00 +0530 Fri, 13 Oct 2017 09:18:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=195053 The High Court upheld the Transfer Pricing Officer's jurisdiction to make adjustments on Advertising, Marketing, and Promotion (AMP) expenses, categorizing them as international transactions under Section 92B of the Income Tax Act, 1961. The court emphasized the need for a detailed functional and comparability analysis, rejecting the 'bright line test' and directing a practical approach for determining the Arms Length Price (ALP). The case was remitted back to the Assessing Officer/Transfer Pricing Officer for fresh determination following the High Court's guidance. Case-Laws Income Tax Wed, 28 Oct 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=195053