https://www.taxtmi.com/caselaws?id=349843 AMP expenditure could not be treated as an international transaction absent any agreement, arrangement or understanding requiring spend for the associated enterprise's benefit, and the bright line approach alone was insufficient; the transfer pricing adjustment was deleted. No separate arm's length adjustment could be made for delayed receivables where the main international transactions had already been benchmarked under TNMM, so that adjustment was also deleted. Data processing receipts of Unit II remained eligible for section 10A deduction on consistent facts and prior judicial approval, and section 14A read with Rule 8D could not apply in the absence of exempt income, so that disallowance was deleted. Interest on income-tax refund under section 244A was remanded for factual verification and fresh adjudication. en-us Mon, 23 Oct 2017 00:00:00 +0530 Thu, 27 Oct 2022 18:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=349843 AMP expenditure could not be treated as an international transaction absent any agreement, arrangement or understanding requiring spend for the associated enterprise's benefit, and the bright line approach alone was insufficient; the transfer pricing adjustment was deleted. No separate arm's length adjustment could be made for delayed receivables where the main international transactions had already been benchmarked under TNMM, so that adjustment was also deleted. Data processing receipts of Unit II remained eligible for section 10A deduction on consistent facts and prior judicial approval, and section 14A read with Rule 8D could not apply in the absence of exempt income, so that disallowance was deleted. Interest on income-tax refund under section 244A was remanded for factual verification and fresh adjudication. Case-Laws Income Tax Mon, 23 Oct 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=349843