https://www.taxtmi.com/highlights?id=90801 The ITAT deleted the Transfer Pricing adjustment relating to AMP expenses incurred by the appellant as an international transaction under section 92B. The tribunal relied on its coordinate bench's precedent, holding that since the appellant demonstrated arm's length remuneration from distribution services, including subvention income exceeding the adjustment amount, no further addition was justified. The TPO's reliance on the Bright Line Test was rejected as lacking statutory basis. Consequently, the impugned Transfer Pricing adjustment was set aside, and the appellant's appeal on this ground was allowed. en-us Wed, 23 Jul 2025 08:29:49 +0530 Wed, 23 Jul 2025 08:29:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=90801 The ITAT deleted the Transfer Pricing adjustment relating to AMP expenses incurred by the appellant as an international transaction under section 92B. The tribunal relied on its coordinate bench's precedent, holding that since the appellant demonstrated arm's length remuneration from distribution services, including subvention income exceeding the adjustment amount, no further addition was justified. The TPO's reliance on the Bright Line Test was rejected as lacking statutory basis. Consequently, the impugned Transfer Pricing adjustment was set aside, and the appellant's appeal on this ground was allowed. Highlights Income Tax Wed, 23 Jul 2025 08:29:49 +0530 https://www.taxtmi.com/highlights?id=90801