https://www.taxtmi.com/caselaws?id=756339 ITAT Delhi held that an alleged AMP adjustment could not stand where the Revenue failed to establish any international transaction beyond reimbursed marketing es, and a bright line or intensity-based approach could not enlarge the disclosed transaction; the adjustment was deleted. It also rejected Revenue's comparable sets across the trading, networking and manufacturing segments where entities were functionally dissimilar or lacked reliable data, while permitting suitable segmental comparables where record support existed. Royalty could not be separately benchmarked when intrinsically linked to the tested manufacturing segment under TNMM, and CUP adjustments based on dissimilar arrangements were rejected. Expatriate salary paid during secondment was held to be business expenditure and not disallowable. en-us Mon, 29 Jul 2024 00:00:00 +0530 Sat, 04 Jul 2026 10:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=756339 ITAT Delhi held that an alleged AMP adjustment could not stand where the Revenue failed to establish any international transaction beyond reimbursed marketing es, and a bright line or intensity-based approach could not enlarge the disclosed transaction; the adjustment was deleted. It also rejected Revenue's comparable sets across the trading, networking and manufacturing segments where entities were functionally dissimilar or lacked reliable data, while permitting suitable segmental comparables where record support existed. Royalty could not be separately benchmarked when intrinsically linked to the tested manufacturing segment under TNMM, and CUP adjustments based on dissimilar arrangements were rejected. Expatriate salary paid during secondment was held to be business expenditure and not disallowable. Case-Laws Income Tax Mon, 29 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=756339