https://www.taxtmi.com/caselaws?id=395451 AMP expenditure in the manufacturing and distribution segments was held not to constitute an international transaction in the absence of tangible material showing any agreement, understanding, or action in concert with the associated enterprise; the use of a bright line approach to first infer the transaction was rejected, and the transfer pricing additions were deleted. The disallowance under section 40(a)(ia) concerning reimbursements of trade schemes to sales promoters turned on whether the payments were commission or mere reimbursement/trade incentives; as the character of the payments required factual verification, the matter was restored for fresh adjudication. en-us Fri, 15 May 2020 00:00:00 +0530 Thu, 21 May 2020 11:49:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=395451 AMP expenditure in the manufacturing and distribution segments was held not to constitute an international transaction in the absence of tangible material showing any agreement, understanding, or action in concert with the associated enterprise; the use of a bright line approach to first infer the transaction was rejected, and the transfer pricing additions were deleted. The disallowance under section 40(a)(ia) concerning reimbursements of trade schemes to sales promoters turned on whether the payments were commission or mere reimbursement/trade incentives; as the character of the payments required factual verification, the matter was restored for fresh adjudication. Case-Laws Income Tax Fri, 15 May 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=395451