https://www.taxtmi.com/caselaws?id=775302 The ITAT Mumbai deleted the Transfer Pricing adjustment on AMP expenses treated as an international transaction under section 92B. The Tribunal relied on a coordinate bench decision in the assessee's own case, which held that once the assessee demonstrates an arm's length margin including subvention income exceeding the adjustment, no further adjustment is warranted. The Tribunal rejected the TPO's reliance on the Bright Line Test, previously held to lack statutory mandate by the Delhi HC. Consequently, the impugned Transfer Pricing adjustment was deleted and the ground raised by the assessee was allowed. en-us Mon, 30 Jun 2025 00:00:00 +0530 Wed, 23 Jul 2025 08:29:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=775302 The ITAT Mumbai deleted the Transfer Pricing adjustment on AMP expenses treated as an international transaction under section 92B. The Tribunal relied on a coordinate bench decision in the assessee's own case, which held that once the assessee demonstrates an arm's length margin including subvention income exceeding the adjustment, no further adjustment is warranted. The Tribunal rejected the TPO's reliance on the Bright Line Test, previously held to lack statutory mandate by the Delhi HC. Consequently, the impugned Transfer Pricing adjustment was deleted and the ground raised by the assessee was allowed. Case-Laws Income Tax Mon, 30 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=775302