https://www.taxtmi.com/caselaws?id=411375 The Tribunal dismissed the revenue's appeal and allowed the assessee's appeal, directing the deletion of the addition of Rs. 11,46,01,751/- in respect of AMP expenses made by the Assessing Officer. The Tribunal upheld the rejection of the Bright Line Test for benchmarking AMP expenses, excluded routine selling and distribution expenses from AMP expenses, and found no merit in using the Prime Lending Rate for computing markup. It also ruled that AMP expenses incurred unilaterally in India were not an international transaction and that Transfer Pricing adjustments could not determine the quantum of business expenditure. Penalty proceedings under Section 271(1)(c) were not justified. en-us Mon, 16 Aug 2021 00:00:00 +0530 Mon, 23 Aug 2021 13:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=411375 The Tribunal dismissed the revenue's appeal and allowed the assessee's appeal, directing the deletion of the addition of Rs. 11,46,01,751/- in respect of AMP expenses made by the Assessing Officer. The Tribunal upheld the rejection of the Bright Line Test for benchmarking AMP expenses, excluded routine selling and distribution expenses from AMP expenses, and found no merit in using the Prime Lending Rate for computing markup. It also ruled that AMP expenses incurred unilaterally in India were not an international transaction and that Transfer Pricing adjustments could not determine the quantum of business expenditure. Penalty proceedings under Section 271(1)(c) were not justified. Case-Laws Income Tax Mon, 16 Aug 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=411375