https://www.taxtmi.com/caselaws?id=423497 The appeals of the Revenue were dismissed, and the appeals of the assessee were allowed. The Court held that the AMP expenditure should not be treated as an international transaction due to insufficient evidence of an agreement or arrangement between the appellant and the associated enterprise. The Court also directed the inclusion of four previously rejected comparables and allowed the netting of interest paid or receivables. The judgment emphasized the requirement for concrete evidence to establish AMP expenditure as an international transaction and rejected the TPO's use of the bright line test for determining the ALP of AMP expenses. en-us Fri, 20 May 2022 00:00:00 +0530 Wed, 08 Jun 2022 09:41:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=423497 The appeals of the Revenue were dismissed, and the appeals of the assessee were allowed. The Court held that the AMP expenditure should not be treated as an international transaction due to insufficient evidence of an agreement or arrangement between the appellant and the associated enterprise. The Court also directed the inclusion of four previously rejected comparables and allowed the netting of interest paid or receivables. The judgment emphasized the requirement for concrete evidence to establish AMP expenditure as an international transaction and rejected the TPO's use of the bright line test for determining the ALP of AMP expenses. Case-Laws Income Tax Fri, 20 May 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=423497