https://www.taxtmi.com/caselaws?id=303293 Transfer pricing adjustments for AMP expenditure in the manufacturing and distribution segments were unsustainable because no arrangement, understanding, or concerted action showed that the assessee incurred such spend for brand building of the associated enterprise; the AMP additions were deleted. Alternative adjustments for royalty, marketing support services, and consultancy services also failed because the Transfer Pricing Officer applied a benefit-based test rather than determining arm's length price through the prescribed Chapter X methods; those additions were deleted as well. The assessment was set aside to the extent of the disputed transfer pricing additions, granting full relief to the assessee. en-us Fri, 17 Jan 2020 00:00:00 +0530 Tue, 12 Jul 2022 20:31:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=303293 Transfer pricing adjustments for AMP expenditure in the manufacturing and distribution segments were unsustainable because no arrangement, understanding, or concerted action showed that the assessee incurred such spend for brand building of the associated enterprise; the AMP additions were deleted. Alternative adjustments for royalty, marketing support services, and consultancy services also failed because the Transfer Pricing Officer applied a benefit-based test rather than determining arm's length price through the prescribed Chapter X methods; those additions were deleted as well. The assessment was set aside to the extent of the disputed transfer pricing additions, granting full relief to the assessee. Case-Laws Income Tax Fri, 17 Jan 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=303293