https://www.taxtmi.com/caselaws?id=430557 Transfer pricing adjustment on alleged AMP-related international transaction was rejected because the Revenue failed to show any agreement, arrangement, or material evidencing that the assessee incurred AMP expenditure for its AE's brand promotion. The TPO's inference of an international transaction based merely on the quantum of AMP spend and application of the BLT was held impermissible, being contrary to the HC rulings in Maruti Suzuki and Bausch Lomb. The Revenue's plea for remand on the basis that the assessee was a distributor was declined since, unlike Sony Ericsson, no contractual terms were shown to support an AMP transaction. The ITAT's deletion of the AMP adjustment was upheld and the appeal was dismissed. en-us Wed, 02 Nov 2022 00:00:00 +0530 Tue, 06 Jan 2026 14:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=430557 Transfer pricing adjustment on alleged AMP-related international transaction was rejected because the Revenue failed to show any agreement, arrangement, or material evidencing that the assessee incurred AMP expenditure for its AE's brand promotion. The TPO's inference of an international transaction based merely on the quantum of AMP spend and application of the BLT was held impermissible, being contrary to the HC rulings in Maruti Suzuki and Bausch Lomb. The Revenue's plea for remand on the basis that the assessee was a distributor was declined since, unlike Sony Ericsson, no contractual terms were shown to support an AMP transaction. The ITAT's deletion of the AMP adjustment was upheld and the appeal was dismissed. Case-Laws Income Tax Wed, 02 Nov 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=430557