https://www.taxtmi.com/caselaws?id=776989 ITAT, DELHI (AT) held that AMP benchmarking via a Bright Line Test or intensity approach is not permissible under Chapter X; both substantive and protective AMP adjustments were deleted. The royalty TP adjustment was rejected and deleted; AO directed to remove the combined TNMM benchmarking and apply CUP as appropriate. For business-support services the TPO was directed to exclude one comparable and rework adjustments. CSR disallowance was decided for the taxpayer and royalty expenses examined under s.37(1) are to be allowed. Warranty provision disallowance was deleted. MTM loss issue was remitted to the AO for computation to avoid double taxation. DDT ground was decided against the taxpayer. en-us Fri, 08 Aug 2025 00:00:00 +0530 Wed, 20 Aug 2025 12:02:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=776989 ITAT, DELHI (AT) held that AMP benchmarking via a Bright Line Test or intensity approach is not permissible under Chapter X; both substantive and protective AMP adjustments were deleted. The royalty TP adjustment was rejected and deleted; AO directed to remove the combined TNMM benchmarking and apply CUP as appropriate. For business-support services the TPO was directed to exclude one comparable and rework adjustments. CSR disallowance was decided for the taxpayer and royalty expenses examined under s.37(1) are to be allowed. Warranty provision disallowance was deleted. MTM loss issue was remitted to the AO for computation to avoid double taxation. DDT ground was decided against the taxpayer. Case-Laws Income Tax Fri, 08 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=776989