https://www.taxtmi.com/caselaws?id=465731 AMP expenditure on the facts did not constitute an international transaction under section 92B read with section 92F(v) of the Income-tax Act, 1961, because the record showed no agreement, arrangement, understanding, invoice or other material linking the spend to the foreign associated enterprise. Transfer pricing methods such as the bright line test and residual profit split method could not by themselves establish the existence of an international transaction. The expenditure was treated as part of the assessee's own business functions in selling IT products and services in India, and the proposed transfer pricing adjustment on this account was therefore unsustainable. en-us Fri, 24 Jan 2025 00:00:00 +0530 Tue, 06 Jan 2026 22:17:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465731 AMP expenditure on the facts did not constitute an international transaction under section 92B read with section 92F(v) of the Income-tax Act, 1961, because the record showed no agreement, arrangement, understanding, invoice or other material linking the spend to the foreign associated enterprise. Transfer pricing methods such as the bright line test and residual profit split method could not by themselves establish the existence of an international transaction. The expenditure was treated as part of the assessee's own business functions in selling IT products and services in India, and the proposed transfer pricing adjustment on this account was therefore unsustainable. Case-Laws Income Tax Fri, 24 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465731