Transfer Pricing Officer's Bright Line Test Invalidated in AMP Expenditure Case; Lacks Explicit Assessee-AE Arrangement.

Transfer Pricing Officer's Bright Line Test Invalidated in AMP Expenditure Case; Lacks Explicit Assessee-AE Arrangement. https://www.taxtmi.com/highlights?id=54696 Transfer Pricing Adjustment - adjustment against AMP expenditure - Bright Line Test (BLT) - BLT method as adopted by Ld. TPO was not a valid method to benchmark the transactions. The technical collaboration agreement as referred to by Ld. TPO did not envisage any such express arrangement / agreement between the assessee and its AE and therefore, the same could not support the case of the revenue. - AT en-us Thu, 10 Sep 2020 10:14:43 +0530 Thu, 10 Sep 2020 10:14:43 +0530 TaxTMI RSS Generator Transfer Pricing Officer's Bright Line Test Invalidated in AMP Expenditure Case; Lacks Explicit Assessee-AE Arrangement. https://www.taxtmi.com/highlights?id=54696 Transfer Pricing Adjustment - adjustment against AMP expenditure - Bright Line Test (BLT) - BLT method as adopted by Ld. TPO was not a valid method to benchmark the transactions. The technical collaboration agreement as referred to by Ld. TPO did not envisage any such express arrangement / agreement between the assessee and its AE and therefore, the same could not support the case of the revenue. - AT Highlights Income Tax Thu, 10 Sep 2020 10:14:43 +0530 https://www.taxtmi.com/highlights?id=54696