https://www.taxtmi.com/caselaws?id=768564 Excessive Advertisement, Marketing and Promotion expenditure by itself does not establish an international transaction for transfer pricing purposes. Chapter X permits substitution of the transaction price with arm's length price only after the Revenue first proves, by tangible material, that an agreement, understanding, or arrangement exists between the assessee and its associated enterprise. The bright line test is not a permissible method to identify such a transaction or to compute arm's length price. In the absence of foundational evidence of an international transaction, the remand to the Transfer Pricing Officer was unwarranted and the AMP adjustment could not be sustained. en-us Mon, 10 Feb 2025 00:00:00 +0530 Wed, 09 Apr 2025 07:42:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=768564 Excessive Advertisement, Marketing and Promotion expenditure by itself does not establish an international transaction for transfer pricing purposes. Chapter X permits substitution of the transaction price with arm's length price only after the Revenue first proves, by tangible material, that an agreement, understanding, or arrangement exists between the assessee and its associated enterprise. The bright line test is not a permissible method to identify such a transaction or to compute arm's length price. In the absence of foundational evidence of an international transaction, the remand to the Transfer Pricing Officer was unwarranted and the AMP adjustment could not be sustained. Case-Laws Income Tax Mon, 10 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=768564