https://www.taxtmi.com/caselaws?id=306465 AMP expenditure could not be finally adjusted without first establishing, on the parties' actual conduct and a proper FAR analysis, that the assessee was obliged to incur such spend for promoting the associated enterprise's brand. The record and the transfer pricing study did not adequately show the existence of an AMP-related international transaction or its arm's length price. The AMP adjustment was therefore set aside and the matter remitted to the Transfer Pricing Officer for fresh examination of whether an international transaction existed and, if so, whether any ALP adjustment was warranted. en-us Fri, 27 Jul 2018 00:00:00 +0530 Tue, 31 Jan 2023 22:07:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=306465 AMP expenditure could not be finally adjusted without first establishing, on the parties' actual conduct and a proper FAR analysis, that the assessee was obliged to incur such spend for promoting the associated enterprise's brand. The record and the transfer pricing study did not adequately show the existence of an AMP-related international transaction or its arm's length price. The AMP adjustment was therefore set aside and the matter remitted to the Transfer Pricing Officer for fresh examination of whether an international transaction existed and, if so, whether any ALP adjustment was warranted. Case-Laws Income Tax Fri, 27 Jul 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306465