https://www.taxtmi.com/caselaws?id=306197 The Tribunal allowed the appeal of the assessee, directing the AO to delete transfer pricing adjustments concerning Advertisement, Marketing, and Promotion (AMP) expenses. It held that without an explicit agreement or understanding between the parties, such expenses do not constitute an international transaction. The Tribunal emphasized the importance of consistency in judicial decisions and rejected the application of Bright Line Test (BLT) for benchmarking AMP expenses. The TPO's invocation of Chapter X of the Act for AMP expenses was deemed incorrect, leading to the deletion of the adjustments. en-us Mon, 31 May 2021 00:00:00 +0530 Mon, 16 Jan 2023 20:28:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=306197 The Tribunal allowed the appeal of the assessee, directing the AO to delete transfer pricing adjustments concerning Advertisement, Marketing, and Promotion (AMP) expenses. It held that without an explicit agreement or understanding between the parties, such expenses do not constitute an international transaction. The Tribunal emphasized the importance of consistency in judicial decisions and rejected the application of Bright Line Test (BLT) for benchmarking AMP expenses. The TPO's invocation of Chapter X of the Act for AMP expenses was deemed incorrect, leading to the deletion of the adjustments. Case-Laws Income Tax Mon, 31 May 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306197