https://www.taxtmi.com/caselaws?id=771116 In the absence of a proved arrangement or agreement showing an international transaction, advertisement, marketing and promotion expenditure incurred with third parties could not be benchmarked under transfer pricing, and the Bright Line Test was not accepted as a valid basis for arm's length pricing. The Tribunal also held that comparables must match the actual functional profile of the assessee: where the assessee rendered IT support services and did not develop software or own related intellectual property, software development companies were not appropriate comparables. On both issues, the transfer pricing adjustments were deleted, and the assessee's position was accepted. en-us Mon, 21 Apr 2025 00:00:00 +0530 Wed, 21 May 2025 08:29:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=771116 In the absence of a proved arrangement or agreement showing an international transaction, advertisement, marketing and promotion expenditure incurred with third parties could not be benchmarked under transfer pricing, and the Bright Line Test was not accepted as a valid basis for arm's length pricing. The Tribunal also held that comparables must match the actual functional profile of the assessee: where the assessee rendered IT support services and did not develop software or own related intellectual property, software development companies were not appropriate comparables. On both issues, the transfer pricing adjustments were deleted, and the assessee's position was accepted. Case-Laws Income Tax Mon, 21 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=771116