https://www.taxtmi.com/caselaws?id=432822 AMP expenditure was not treated as an international transaction for transfer pricing purposes because no formal or informal arrangement showed that the assessee incurred the spend on behalf of the associated enterprise. The Tribunal held that an incidental benefit to the foreign group entity was insufficient to establish the foundational international transaction required under Chapter X, so benchmarking the AMP spend and applying the bright line test did not arise. The objection on admission of new evidence was not supported by the order and did not call for separate adjudication. en-us Thu, 29 Dec 2022 00:00:00 +0530 Sat, 14 Jan 2023 07:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=432822 AMP expenditure was not treated as an international transaction for transfer pricing purposes because no formal or informal arrangement showed that the assessee incurred the spend on behalf of the associated enterprise. The Tribunal held that an incidental benefit to the foreign group entity was insufficient to establish the foundational international transaction required under Chapter X, so benchmarking the AMP spend and applying the bright line test did not arise. The objection on admission of new evidence was not supported by the order and did not call for separate adjudication. Case-Laws Income Tax Thu, 29 Dec 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=432822