https://www.taxtmi.com/caselaws?id=762178 Transfer pricing disputes over AMP expenses turned on whether such expenditure constituted an international transaction under Section 92B and whether the Bright Line Test could justify an adjustment. The text states that the Delhi HC found no proved international transaction involving AMP expenses between the company and its AE, upheld deletion of the addition under Section 37, and rejected re-characterization of the arrangement. The SC then declined to entertain the Special Leave Petitions under Article 136 and dismissed them. en-us Wed, 20 Nov 2024 00:00:00 +0530 Wed, 29 Apr 2026 18:03:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=762178 Transfer pricing disputes over AMP expenses turned on whether such expenditure constituted an international transaction under Section 92B and whether the Bright Line Test could justify an adjustment. The text states that the Delhi HC found no proved international transaction involving AMP expenses between the company and its AE, upheld deletion of the addition under Section 37, and rejected re-characterization of the arrangement. The SC then declined to entertain the Special Leave Petitions under Article 136 and dismissed them. Case-Laws Income Tax Wed, 20 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=762178