https://www.taxtmi.com/caselaws?id=428714 The Tribunal ruled in favor of the assessee, determining that the AMP expenditure did not constitute an international transaction as there was no agreement with the associated enterprise (AE). It was established that the AMP expenses were solely for the assessee's business purposes, promoting specific products rather than the brand. The Tribunal rejected the application of the Bright Line Test and found the comparables chosen by the Transfer Pricing Officer inappropriate. Additionally, the Tribunal noted the absence of royalty payments for the brand name and concluded that the AMP expenses were not for brand promotion. Penalty proceedings were not addressed as the primary appeal favored the assessee. en-us Wed, 06 Jul 2022 00:00:00 +0530 Sat, 08 Oct 2022 13:09:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=428714 The Tribunal ruled in favor of the assessee, determining that the AMP expenditure did not constitute an international transaction as there was no agreement with the associated enterprise (AE). It was established that the AMP expenses were solely for the assessee's business purposes, promoting specific products rather than the brand. The Tribunal rejected the application of the Bright Line Test and found the comparables chosen by the Transfer Pricing Officer inappropriate. Additionally, the Tribunal noted the absence of royalty payments for the brand name and concluded that the AMP expenses were not for brand promotion. Penalty proceedings were not addressed as the primary appeal favored the assessee. Case-Laws Income Tax Wed, 06 Jul 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=428714