https://www.taxtmi.com/caselaws?id=406998 AMP expenditure could not be treated as an international transaction for transfer pricing purposes merely because it was higher than that of comparables. The ITAT Delhi held that the Revenue must first establish, with tangible material, an arrangement, understanding, or conduct in concert between the assessee and its associated enterprise before making any arm's length price adjustment. The bright line test could not be used to infer the existence of the transaction at the threshold, and prior orders in the assessee's own case had already accepted that no AMP international transaction existed. The transfer pricing adjustment on account of AMP was therefore deleted. en-us Mon, 19 Oct 2020 00:00:00 +0530 Fri, 30 Apr 2021 10:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=406998 AMP expenditure could not be treated as an international transaction for transfer pricing purposes merely because it was higher than that of comparables. The ITAT Delhi held that the Revenue must first establish, with tangible material, an arrangement, understanding, or conduct in concert between the assessee and its associated enterprise before making any arm's length price adjustment. The bright line test could not be used to infer the existence of the transaction at the threshold, and prior orders in the assessee's own case had already accepted that no AMP international transaction existed. The transfer pricing adjustment on account of AMP was therefore deleted. Case-Laws Income Tax Mon, 19 Oct 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=406998