https://www.taxtmi.com/caselaws?id=371342 An AMP transfer pricing adjustment cannot rest on the Bright Line Test alone. The Tribunal noted that higher advertisement, marketing and promotion spend does not by itself establish an international transaction or permit benchmarking unless the revenue first proves, with tangible material, an arrangement or acting in concert between the assessee and its associated enterprise. In the absence of such evidence, the expenditure could not be treated as an international transaction or sustained on the revenue's adopted method, and the assessee succeeded on this issue. en-us Mon, 26 Nov 2018 00:00:00 +0530 Mon, 03 Dec 2018 09:04:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=371342 An AMP transfer pricing adjustment cannot rest on the Bright Line Test alone. The Tribunal noted that higher advertisement, marketing and promotion spend does not by itself establish an international transaction or permit benchmarking unless the revenue first proves, with tangible material, an arrangement or acting in concert between the assessee and its associated enterprise. In the absence of such evidence, the expenditure could not be treated as an international transaction or sustained on the revenue's adopted method, and the assessee succeeded on this issue. Case-Laws Income Tax Mon, 26 Nov 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=371342