https://www.taxtmi.com/article/detailed?id=11283 Mere use of a foreign associated enterprise's brand by an Indian licensee does not automatically convert AMP expenditures into an international transaction; the revenue must prove an agreement/arrangement/understanding obliging the assessee to spend for the AE, and factors like toll manufacture, procurement of inputs, and branded product names alone do not establish such an arrangement. Taxpayers should maintain intercompany arrangements, transfer pricing documentation, cost sheets/MIS showing AMP costs embedded in pricing, and evidence that AMP decisions are made independently. en-us Wed, 05 Apr 2023 09:02:03 +0530 Wed, 05 Apr 2023 09:02:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/article/detailed?id=11283 Mere use of a foreign associated enterprise's brand by an Indian licensee does not automatically convert AMP expenditures into an international transaction; the revenue must prove an agreement/arrangement/understanding obliging the assessee to spend for the AE, and factors like toll manufacture, procurement of inputs, and branded product names alone do not establish such an arrangement. Taxpayers should maintain intercompany arrangements, transfer pricing documentation, cost sheets/MIS showing AMP costs embedded in pricing, and evidence that AMP decisions are made independently. Articles Income Tax Wed, 05 Apr 2023 09:02:03 +0530 https://www.taxtmi.com/article/detailed?id=11283