https://www.taxtmi.com/caselaws?id=280780 The High Court discarded the Bright Line Test for Transfer Pricing Adjustment on AMP Expenses due to lack of evidence, resulting in no adjustment warranted. For Transfer Pricing Adjustment on Payment of Royalty, the Arm's Length royalty was determined at 4.05%. Allocation of Asian Region Office Expenses was justified, disallowance of Overseas Marketing-Related Services was sent for reevaluation, and other issues were decided in favor of the assessee. The Tribunal upheld some disallowances and adjustments, emphasizing the importance of evidence in establishing international transactions and applying the arm's length principle. en-us Mon, 14 Jan 2019 00:00:00 +0530 Tue, 21 May 2019 09:46:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=280780 The High Court discarded the Bright Line Test for Transfer Pricing Adjustment on AMP Expenses due to lack of evidence, resulting in no adjustment warranted. For Transfer Pricing Adjustment on Payment of Royalty, the Arm's Length royalty was determined at 4.05%. Allocation of Asian Region Office Expenses was justified, disallowance of Overseas Marketing-Related Services was sent for reevaluation, and other issues were decided in favor of the assessee. The Tribunal upheld some disallowances and adjustments, emphasizing the importance of evidence in establishing international transactions and applying the arm's length principle. Case-Laws Income Tax Mon, 14 Jan 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=280780