https://www.taxtmi.com/caselaws?id=371290 AMP expenditure could not be treated as an international transaction for transfer pricing purposes without first proving a factual basis for such transaction, and the Bright Line Test had no statutory mandate. The Tribunal followed the jurisdictional High Court's view that the Revenue must discharge the initial burden of establishing an international transaction before any arm's length price exercise can begin. As the record showed no independent foundation beyond comparable-based and BLT reasoning, the adjustment was held unsustainable in law, with the matter restored to the Assessing Officer for fresh action depending on the outcome of pending higher-court proceedings. en-us Mon, 26 Nov 2018 00:00:00 +0530 Sat, 01 Dec 2018 12:42:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=371290 AMP expenditure could not be treated as an international transaction for transfer pricing purposes without first proving a factual basis for such transaction, and the Bright Line Test had no statutory mandate. The Tribunal followed the jurisdictional High Court's view that the Revenue must discharge the initial burden of establishing an international transaction before any arm's length price exercise can begin. As the record showed no independent foundation beyond comparable-based and BLT reasoning, the adjustment was held unsustainable in law, with the matter restored to the Assessing Officer for fresh action depending on the outcome of pending higher-court proceedings. Case-Laws Income Tax Mon, 26 Nov 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=371290