https://www.taxtmi.com/caselaws?id=307172 Transfer pricing adjustment for advertisement, marketing and promotion expenses was held unsustainable where the Revenue failed to produce tangible material showing an international transaction between the assessee and its associated enterprise. The Tribunal held that the Bright Line Test cannot, by itself, create such a transaction or supply the statutory basis for an adjustment. It also followed Delhi High Court authority that AMP spend incurred for the assessee's own business in a manufacturing case cannot be recharacterised as an international transaction merely because the brand owner may incidentally benefit. The adjustment was deleted. en-us Mon, 31 Aug 2020 00:00:00 +0530 Thu, 23 Mar 2023 20:40:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=307172 Transfer pricing adjustment for advertisement, marketing and promotion expenses was held unsustainable where the Revenue failed to produce tangible material showing an international transaction between the assessee and its associated enterprise. The Tribunal held that the Bright Line Test cannot, by itself, create such a transaction or supply the statutory basis for an adjustment. It also followed Delhi High Court authority that AMP spend incurred for the assessee's own business in a manufacturing case cannot be recharacterised as an international transaction merely because the brand owner may incidentally benefit. The adjustment was deleted. Case-Laws Income Tax Mon, 31 Aug 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=307172